Increment file name in Photoshop action?

A colleague of mine is having a problem with a Photoshop action and I thought I’d see if anybody here might have an answer. He’s trying to create a Photoshop action, the hitch is when it comes to saving the file. He wants to save the scans in a folder and would like to have Photoshop count up with a generic file name instead of overwriting each picture as “Untitled-1.jpg”
Is there a way to prevent Photoshop from overwriting files with the same name in a folder?
He want 100 photos in a folder listed as 1-100 somehow, instead of scanning 100 photos and ending up with one file thats Untitled-1.jpg of the last scan that I made.