"Substantial completion of document production" is not exactly a bright line.
Is it more than half?
More than 90%?
At least in Delaware, cases interpreting the issue are light on the ground. Usually, when presented with a steaming pile of documents after the substantial completion deadline, the parties will work out some modest schedule extension without any court intervention. This is probably for the best, but it means that the parties are usually working from a blank slate when negotiating the necessity and length of any extension.
Luckily for us, Judge Burke issued an Oral Order …