A Practice Note explaining how counsel may use a document production protocol to establish the parties' rights and obligations when producing documents and electronically stored information (ESI) in discovery, whether in response to a Federal Rule of Civil Procedure (FRCP) 34 request for the production of documents (RFP) or an FRCP 45 subpoena. This Note discusses joint and unilateral production protocols and identifies several issues that counsel should address in any production protocol, including production format, metadata, confidential and privileged content, and production organization.