Discovery
Written Discovery
Rolling production serves documents in batches on an agreed schedule, with a substantial completion date establishing when production must be finished. Volumes carry continuous Bates numbering.
The approach is standard in large document productions.
Alternative Names:
Staged Production, Incremental Production
Why it Matters?
Substantial completion is the term that requires definition, since a producing party can technically comply with a rolling schedule while deferring the most significant material to the final volume. Agreeing a firm completion date well before depositions begin, and prioritizing key custodians in early volumes, prevents the schedule from functioning as delay. Tracking what has been produced against the custodian list is the practical check.
Frequently Confused with
Related terms
Frequently asked questions
What is substantial completion?
How should the schedule be structured?
