Rolling Productions

Rolling Productions

Rolling Productions

Rolling production delivers documents as review completes rather than holding everything until the end. Volumes are numbered sequentially with continuous Bates ranges.

Parties typically agree on a schedule and a substantial completion date.

Alternative Names:

Staged Production, Phased Production Delivery

Why it Matters?

Rolling production gets material to the requesting party earlier and spreads the producing party's cost, which suits both sides in large matters. The friction point is substantial completion, since a producing party can technically comply with a rolling schedule while delivering the most significant material last. Agreeing a firm completion date, and prioritizing key custodians in early volumes, prevents the schedule from becoming a delay mechanism.

Frequently asked questions

Why produce on a rolling basis?

Why produce on a rolling basis?

It delivers material earlier for the requesting party and spreads review and production cost for the producing party across the discovery period.

What is the risk to the requesting party?

What is the risk to the requesting party?

That significant custodians and material are deferred to late volumes, which is why prioritization and a firm completion date should be negotiated.