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Discovery

FieldValue
TypeSkill Resource
Source~/.copilot/skills/legal/references/discovery.md
DescriptionNot specified

Source Content

Discovery

Use this reference for interrogatories, requests for production, requests for admission, subpoenas, discovery responses, privilege logs, and meet-and-confer discovery letters.

Structure

Discovery requests should be enforceable on their face. Use definitions, instructions, a defined time period, numbered requests, and a proportionality nexus when a court may later review them.

Common shells

  • Interrogatories: written questions requiring narrative answers under oath.
  • Requests for production: document and ESI requests with format and timeframe instructions.
  • Requests for admission: narrow admissions used to establish or narrow disputed facts.
  • Subpoena duces tecum: third-party document production with specific categories.
  • Motion to compel support packet: combine deficient request, response, meet-and-confer record, and requested order.

Drafting checks

  • One subject per request.
  • Define ambiguous terms.
  • Use date ranges and custodians where helpful.
  • Avoid compound requests that become unenforceable.
  • Tie each request to a claim, defense, support factor, custody factor, or damages issue.