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 Confused with
Related terms
Frequently asked questions
Why produce on a rolling basis?
What is the risk to the requesting party?
