Take Note: Tools For Annotating PDF Seminar Materials

By Beverly M. Burden, Chapter 13 Trustee for the Eastern District of Kentucky

DISCLAIMER: The opinions expressed herein are the personal opinions of the author and do not necessarily reflect the views of the Academy, the NACTT, or the Office of the Chapter 13 Trustee. This article is not an endorsement of any particular product.

I love having PDF files for seminar materials. I have my laptop and/or iPad when I travel anyway, so I don’t want to haul around a ream of paper also. Taking notes during seminar presentations, however, is not as easy as jotting something in the margin of a paper handout, or highlighting a case name on the paper handout for future reference.

Over time, I have experimented with different methods of taking notes during seminars, and when I am writing on my iPad, invariably other attendees ask me “what app are you using?” If you are trying to keep notes with your PDF seminar handouts, here are some options you can try with a laptop or a tablet. We would love to hear your ideas and suggestions.

Using PDF Editing Tools on a Laptop:

Whether you use Adobe Acrobat, PDF Exchange, Nitro Pro, or other PDF software on your laptop, there are editing tools you can use to take notes. In Acrobat, for example, there are tools for “Add sticky note”; “Highlight text”; or “Underline text.” If those tools (and other “Drawing Markups”) are not in the Toolbar at the top of the screen, look on the right side of the Toolbar for “Comment”, which opens up a sidebar with all of the tools you need for taking notes.

In Adobe Acrobat, click on the “Add sticky note” tool, then click on the page where you would like to make a note. A box opens up in which you can type your notes. When you are finished typing, click anywhere on the page, and the sticky note shrinks to a little icon so it stays out of the way. When you need to go back to a particular note, you don’t need to open every sticky note; just look at the “Comments List” in the Comment toolbar.

You can search your notes (separately from searching the text of the PDF document), so if you remember typing “Lanning” somewhere in a note, type “Lanning” in the “find” box at the top of the Comments List, and your note will be displayed. Text that you highlight or underline will also show up in the Comments List, making it easy for you to find the materials you deemed important enough to identify for future reference.

Using Tablet Apps:

There are numerous apps for editing or annotating PDF documents on a tablet, and those editing tools are useful in taking notes during seminar presentations. Since I use an iPad, I’ll describe some of the iPad apps I have used. Some of the apps are also available for Android and other operating systems.

Like a desktop or laptop program, most apps that allow you to open and read PDF files will allow you to add a typewritten sticky note or text box. One nice feature about many note-taking or PDF editing apps is the ability to make handwritten notes on your tablet.1 A word of warning, though: any app that allows you to write on the page has its own quirks, and it takes a bit of time to become accustomed to the process of writing on the tablet in general and the feel of an app in particular.

Some apps you might want to check out (in no particular order) are: GoodNotes, PDF Max, iAnnotate, PDF Reader, Note Taker HD, TopNotes, and Notability. Most apps are in the free to $9.99 range. Try the free ones (or the Lite versions that you can upgrade later) first. Even the free Adobe Reader app has very rudimentary tools for highlighting and underlining text, inserting text boxes, or adding sticky notes.

Once you select an app, importing your seminar PDF files into the app is easy. You can usually download PDF files into the app from the internet or from attachments to emails by opening the PDF document, then using the “Open in . . .” command on the iPad. Most apps also interface with cloud services such as Dropbox, Box, iCloud, Google Drive, etc., allowing you to import your documents from the cloud service into the app, and then sync your notes back to the cloud. However, not all apps interface with all cloud services, so make sure the app you want to purchase will connect to your preferred cloud service.2

Some of the features you’ll see in tablet apps are things like:

  • A palm rest, so you can rest your hand on the screen while writing but the app won’t pick up any marks your hand might make, and as you move your hand the app won’t interpret those movements as scrolling commands.3
  • Choice of colors for ink notes and highlights.
  • Adjustments to the thickness and/or opacity of the ink/highlights.
  • A cut-and-paste tool that allows you to select your handwritten note and move it to another location in the document.
  • Search capabilities.
  • Importing bookmarks (or “outline” or “index”) with the PDF document.
  • Thumbnail views of pages.
  • Ability to save and export annotated documents so your notes are visible when you open the annotated PDF file on your desktop.
  • Ability to insert a blank page in a PDF document for additional notes.
  • Using the microphone built in to the iPad to make an audio recording within (and attached to) the PDF file.
  • A magnification or zoom window that allows you to make more extensive notes in a small area on the page by opening up a larger window in which to write (hard to describe, but it makes sense when you see it in action). Personally, I love this feature (although it takes time to get the feel of how the zoom window moves as you continue to write), and not all apps offer it.

My go-to app is Notability, which is designed for students and teachers but is useful for annotating any PDF file. I like the layout of Notability and the ease with which I can make handwritten notes, but it has a significant draw-back when using it to make notes on seminar materials that come in one large but indexed file – Notability does not import the bookmarks that are already in the PDF document. You can make your own unnamed bookmarks, but when you are trying to scroll through an 800-page PDF file, the app gets sluggish.

As you look at apps, consider whether you would make use of the app for purposes other than reading seminar materials. When I’m doing research, I download cases from Westlaw, import the PDF files into Notability, and mark them up as I would do with paper copies. I have used a different app to sign a document and email it back to the party who needed my signature. Do you use PDF forms or need to be able to preserve your notes? Do you need something for general note-taking (not annotating a PDF file)? Do you need to share files or work collaboratively on a document? Do you need to be able to encrypt certain files (like client intake forms)? Do you need to be able to print your notes from the app?

When looking for an app, often it’s a matter of personal choice – how easy is it to use. Too many bells and whistles, and I spend more time trying to figure it out and less time actually using it effectively. I usually just want to be able to quickly switch from a pen to highlighter to an eraser and back to a pen.


[1] I use an Adonit Jot Pro stylus which has a sharp tip more like a pen than the typical soft-tipped stylus. If all you want to do is highlight or circle text, or write a very short note at the bottom of a page (like the citation to a recent case), your index finger can substitute for a stylus.

[2] And remember that once you give an app access to your cloud account, any PDF file (and other type files, depending on the app) stored in the cloud account can be imported into the app. If your iPad is stolen, go to your cloud account and disable the apps from having access to the cloud account (in addition to remotely erasing your tablet data).

[3] The location of this palm rest can render some apps virtually useless for us left-handers who want to write notes.


burdenBeverly M. Burden, Lexington, Kentucky, has served as the Chapter 13 Trustee for the Eastern District of Kentucky since 1999. From 1987 to 1999, she served as Law Clerk to Bankruptcy Judge Joe Lee. Prior to her tenure with the Bankruptcy Court, she was an Assistant Attorney General for the Commonwealth of Kentucky, where she concentrated on consumer fraud litigation. She earned her J.D. degree from the University of Kentucky College of Law in 1983 and holds a B.B.A. degree in Accounting. Ms. Burden has served on the faculty of the annual meeting of the National Conference of Bankruptcy Judges, the annual convention of the National Association of Chapter Thirteen Trustees, the Midwest Regional Bankruptcy Seminar, the Judge Joe Lee Biennial Bankruptcy Institute, and numerous other regional and local CLE programs. She was the 1997 recipient of the Kentucky Bar Association’s Justice Thomas B. Spain Award For Outstanding Service in Continuing Legal Education.

No Author Biography has been linked to this Article.

Related Articles

January 24, 2021
By Kara K. Gendron, Esquire, Mott & Gendron Law (Harrisburg, PA) The recent Supreme Court decision in City of Chicago v. Fulton1 will change the law in most Circuits. Prior to this case, there was a split among the circuits as to whether the post-petition retention of property taken pre-petition constitutes a violation of the automatic stay under §362(a)(3) of...
September 22, 2019
By The Honorable William Houston Brown (Retired) Tax foreclosure sale avoided as preference. Affirming the District and Bankruptcy Courts, at 571 B.R. 662 and 588 B.R. 394, the Third Circuit held that the Chapter 13 debtors could avoid a pre-petition tax foreclosure sale as a preferential transfer. The township held a properly noticed tax sale at public auction, which resulted...
July 7, 2019
By Henry E. Hildebrand, III, Chapter 13 Standing Trustee for the Middle District of Tennessee (Nashville) Where a confirmation order of a debtor’s Chapter 12 plan specifically provided for payments to a creditor and the Chapter 12 trustee had supported confirmation of the plan, the trustee would be precluded from seeking to disallow a late-filed claim. Following the plan, the...
April 24, 2022
Recent headlines noted that March 2022 saw a 33.5% increase in bankruptcy filings over February. This could suggest the coming swell in bankruptcy cases anticipated since the start of the COVID pandemic. However, bankruptcy professionals recognize that consumer filings always spike in March (see chart). This phenomenon is usually attributed to the tendency to avoid filing in January and February...
April 2, 2023
Consumer law attorney, mentor and educator, Oliver Max Gardner III recently announced that he is retiring. His passion, diligent research and unmatched expertise has served as a north star in consumer law for so many of us. From building a community of like-minded enthusiasts through the renowned Bankruptcy Boot Camp and cultivating an army of consumer litigators to fiercely defending...
December 22, 2019
By William Houston Brown, Editor/Adviser, Academy for Consumer Bankruptcy Education On December 18, 2019, the Supreme Court granted the City of Chicago’s petition for certiorari, 2019 WL 6880702, from the decision of the Seventh Circuit at 926 F.3d 916 (7th Cir. June 19, 2019). The Seventh Circuit’s decision was analyzed in a prior article on this website. In its decision,...
July 31, 2022
It started as a means test question: could emergency medical expenses be deemed non consumer debt. It ended up as a step back to get the bigger picture. Well seasoned bankruptcy counsel brought the fact pattern to a list serve of colleagues. The prospective debtors’ income in a small consulting corporation is declining, his health crisis raises not only income...
November 14, 2021
By Mary Beth Ausbrooks, Rothschild & Ausbrooks PLLC (Nashville, TN) With the prolonged decline in case filings, I found that sending a mass emailed newsletter has been very beneficial. In order to send a mass email to a group of people, it was necessary to find software that would send the emails out in such a fashion that the email...
June 9, 2019
By Jan Hamilton, Chapter 13 Trustee (Topeka, KS) Introduction Preliminarily, I recognize that many of those reading this do not need to. There are many fine trial attorneys in the bankruptcy bar. Those folks could well be writing this article. By way of defending myself in advance, this little piece does not consist of a series of war stories or...
June 11, 2023
Hands up everyone who has encountered a claim that a debt is non-dischargeable by reason of § 523(a)(14). That’s what I thought: nada, or next thing to it. Despite watching for it, I hadn’t seen one ‘til this year when AmEx filed an adversary in a case in which I was peripherally involved. My copy of Collier’s code doesn’t comment...