Affidavi / Guides / Hyperlinking exhibits
How to hyperlink an affidavit to its exhibits
The expectation is simple to state: an affidavit and its exhibits go up as one PDF, and every "attached hereto and marked as Exhibit 'A'" is a working link that takes the reader to Exhibit A. That is how the Superior Court's Case Center guidance describes usable materials, it is what the court directed counsel to do in Parekh v Schecter, 2022 ONSC 302 — and in Basaraba v Bridal Image Inc., 2021 ONSC 8038, a motion was dismissed with missing hyperlinks cited as reason enough on their own.
Why judges care
On a screen there are no tabs to flip. Without links, every exhibit reference sends the judge scrolling through hundreds of pages and back again — for every one of your citations. As Dunphy J. put it in Basaraba, properly hyperlinked records remain "the exception and not the rule," and courts have stopped treating that as acceptable. A linked record is not garnish; it is the difference between the judge reading your evidence and the judge hunting for it.
Building the links by hand
If you assemble manually, the workflow in Adobe Acrobat (or an equivalent editor) looks like this:
- Combine the affidavit and all exhibits into a single PDF, exhibits in lettering order, each behind its exhibit stamp or cover.
- OCR any scanned exhibit so every page has a text layer.
- Bookmark the affidavit and each exhibit ("Exhibit A — Agreement of Purchase and Sale…"), so the sidebar mirrors the record.
- Link each reference. For every mention of an exhibit in the body: draw a link rectangle over the reference text (Edit PDF → Link → Add/Edit), choose "Go to a page view," and set the destination to the exhibit's first page.
- Add return links. A small "back to affidavit" link on each exhibit's first page returns the reader to the paragraph that cited it — judges notice.
- Save and verify. Export or save as PDF — never "print to PDF," which strips every link — then click through each one.
Budget realistically: a 40-exhibit affidavit with multiple references per exhibit is hours of rectangle drawing, and the work repeats every time the record changes.
The pitfalls that quietly break links
- Print-to-PDF. The links survive on your screen until the moment someone "prints" the file to PDF — then they are gone, silently.
- Re-assembly. Inserting, deleting or reordering pages after linking can leave destinations pointing at the wrong pages. Links point at pages, not at exhibits.
- Rotated pages. Link rectangles drawn on rotated scans can land in the wrong place, or the link works while a drawn highlight sits sideways.
- Missing text layer. On a non-OCR'd page there is no text to find — references inside scanned documents can't even be located, let alone linked.
- Lookalike labels. Document numbers like "EXHIBIT 2-05" printed inside an exhibit are not references to Exhibit 2 — naive linking mints phantom targets.
- Re-lettering. Add one exhibit in the middle and every subsequent letter shifts; each affected reference and bookmark has to be found and redone.
Or let the software do the tedious part
Affidavi reads the affidavit, finds every exhibit reference, and builds the record with the links in both directions — covers and stamps, bookmarks, back buttons, rotated pages handled, lookalike labels ignored — in one pass, on your computer. Re-assemble the record and the links are rebuilt, not broken.
Exhibit linking that holds up.
References link to exhibits; every exhibit carries a back button to the paragraph that cites it. Launching soon for macOS and Windows with a 14-day free trial.
See pricing & get notifiedSources: SCJ: How to Organize & Upload Documents · Consolidated Civil Provincial Practice Direction · Parekh v Schecter, 2022 ONSC 302 · Basaraba v Bridal Image Inc., 2021 ONSC 8038 · See also: preparing an electronic motion record
General information about Ontario procedure, not legal advice. Verify against the current Rules and the practice direction that applies to your matter.