Following up on a previous post, I want to pass along another tip I heard recently from a lawyer who has tried many document-intensive cases.
In cases in which exhibits are numbered before trial--most document-intensive cases, in other words--there won't be any requirement that documents be received into evidence in the order that they are numbered. This means that you order and mark exhibits in whatever order you want.
How can you use this to emphasize your best exhibits to the jury? If the jury will be taking the exhibits with them to the jury room after the trial is over, Exhibit 1 should be the document you most want the jury to see. It will be on the top of the stack. Exhibit 2 should be the second-most-important document, and so on, through at least the first twenty exhibits.
Not a bad idea, but it means that the chief trial lawyer will have to have some input into the task of exhibit-numbering, which in large cases, is often delegated to paralegals or junior associates.