I would only count them as one thing if I sorted them in the one session. And if they were all the same category/from the same source. So, ooh, file of psych 100 notes that hasn't been opened in twenty years? Open, pull out the papers, recycle -> 1 thing. But a file of journal articles I had to go through and decide on the relevance of each? Each one gone counts.

And I count anything where I break the tape of '...but this might be useful..." or ".. I was keeping that in case ...".