Spent yesterday reconciling a 32-tab workbook named FINAL_FINAL_v9.xlsx for a Rule 1006 summary, only to discover the ‘authoritative’ figures hid in a JPEG attachment and a cash ledger with Bates gaps from BN-012346 to BN-012350. Anyone else draft affidavits that read like detective novels just to explain why Exhibit 12-B is Exhibit 12-B(ish)?
I started putting a tiny “source grid” on page 1 — each figure ties to Bates (BN-012346-BN-012350), file type (incl. “authoritative” JPEGs), and a SHA-256, so the affidavit doesn’t read like noir and Exhibit 12-B stays 12-B(ish). If there’s a gap, I mark it “intentionally absent — see custodian note” and cite the email or chain-of-custody ID; adds a minute but saves the debrief. Do you ever get pushback from @counsel on hashing images as sources?
When ‘FINAL_FINAL_v9.xlsx’ lands, I export every tab to CSV, hash each CSV and that “authoritative” JPEG with SHA-256, and cite the hashes plus the export timestamp in a one-page Provenance appendix. For the BN-012346–BN-012350 gap, I drop a visible Bates stub row in the schedule naming the missing range and custodian so 12‑B(ish) reads straight. I also embed the JPEG in a PDF/A with OCR and log its EXIF via ExifTool (https://exiftool.org), which has saved me from three “where did that number come from” sidebars.