When discussing how e-discovery is different from paper discovery, a major point to be addressed is how we uniquely identify documents. Paper allows us to create a unique identifier (Bates Number) for each page in the collection. However, ESI is stored and managed at the document level…. not the page level. This means that you can only uniquely assign an ID at the document level. The “doc ID” is usually a “counter number” assigned to the document during processing and has little or no meaning to the case itself (ie. ABC000001, ABC00002). The document ID is not the production number. The production number is more like a Bates Number in that if the documents are converted to TIFF images for the production, then they are “virtually” paper and so can be identified at the page level. If ESI documents are produced in their native format, then they are typically assigned a production number at the document level.