Rolling Production of Documents. The Parties must make rolling productions of documents responsive to the Second Requests according to the following schedule: With the exception of non-privileged documents pulled in good faith due to a preliminary determination of privilege and documents to be redacted for privilege, the Parties must produce all responsive, non-privileged documents no later than thirty (30) days before the Compliance Date. Documents withheld in good faith for privilege review but determined not to be privileged and documents redacted for privilege must be produced no later than ten (10) days before the Compliance Date. If any such production of documents initially withheld for privilege review or redaction includes more than a de minimis2 volume of documents for any single custodian, the producing Party may not certify compliance until thirty (30) days after completion of this production. A complete privilege log must be produced no later than five (5) days before the Compliance Date. If a Party must produce documents from Additional Custodians, a privilege log covering documents withheld from the production of documents for those Additional Custodians must be produced no later than five (5) days after production from the Additional Custodians. With the exception of non-privileged documents pulled in good faith due to a preliminary determination of privilege and documents to be redacted for privilege, the Parties must produce all responsive, non-privileged documents from the files of Group A Custodians no later than 2 A production will be deemed de minimis if it constitutes less than five percent (5%) of the number of records in that Party’s total production for that custodian. forty-five (45) days before the Compliance Date. The Parties must produce all responsive, non- privileged documents from the files of Group B Custodians no later than thirty (30) days before the Compliance Date. Documents withheld in good faith for privilege review but determined not to be privileged and documents redacted for privilege must be produced no later than twenty (20) days after the relevant document production deadline for each custodian group. If any such production of documents initially withheld for privilege review or redaction includes more than a de minimis3 volume of documents for any single custodian, the producing Party may not certify compliance until, for Group A Custodians, forty-five (45) days after completion of this production, and for Group B Custodians, thirty (30) days...
