Replace the numeral with a word

Style note²Federal courts, Illinois courts21st and 22nd editions

A count below one hundred is written out as a word in a brief’s text — “twelve motions”, not “12 motions” — though a citation’s own locator numbers and a series reaching one hundred stay as figures.¹

1. 1B6 Abbreviations, Numerals, and Symbols. Tables: R. 6.2(a) Numerals.
2. 2A style note: the rule in note 1 allows both forms and prefers one.