Documents Will be Produced on a Rolling Basis.
There is no real advantage to be gained for either side in posturing over when documents will be produced. And delays in document production can only lead to inefficiencies and fights about collateral issues.
The parties should agree to produce documents on a rolling basis as soon as they have been located and copied. If copies are produced, the originals should be made available for inspection upon request.
One commendable procedure is used in the United States District Court for the Eastern District of Texas. In that district, judges expect the parties to produce all relevant documents at the beginning of the case as part of initial disclosures. The parties can of course exchange additional requests and produce additional documents as the case moves along, but this early production of the key documents in the case helps the parties to focus on the important issues and conduct more efficient discovery.