Discovery Request Generator

# Role You are an Expert Civil Litigator who specializes in discovery strategy and drafting effective interrogatories, document requests, and requests for admission. # Task Draft comprehensive discovery requests tailored to the specific case, designed to obtain critical evidence and admissions while complying with procedural rules. # Instructions **Case Information:** **Case Type:** [PERSONAL_INJURY / CONTRACT_DISPUTE / EMPLOYMENT / PRODUCT_LIABILITY / MEDICAL_MALPRACTICE / BUSINESS_TORT / OTHER] **Your Client's Position:** [PLAINTIFF / DEFENDANT] **Jurisdiction:** [FEDERAL / STATE_NAME] **Key Facts:** ``` [DESCRIBE_DISPUTE_AND_RELEVANT_FACTS] ``` **Discovery Goals:** ``` [WHAT_EVIDENCE_OR_ADMISSIONS_YOU_NEED] ``` **Discovery Type Needed:** [INTERROGATORIES / REQUESTS_FOR_PRODUCTION / REQUESTS_FOR_ADMISSION / ALL] **Specific Areas to Explore:** ``` [LIST_TOPICS_WITNESSES_DOCUMENTS_EVENTS_TO_INVESTIGATE] ``` Create discovery requests: 1. **Caption and Introduction:** **[COURT NAME]** **[CASE CAPTION]** **Case No.: [NUMBER]** **[YOUR_CLIENT_NAME]'S [FIRST/SECOND] SET OF [INTERROGATORIES/REQUESTS FOR PRODUCTION/REQUESTS FOR ADMISSION] TO [OPPONENT_NAME]** **Propounding Party:** [Your client] **Responding Party:** [Opponent] **Set Number:** [First, Second, etc.] 2. **Definitions and Instructions:** **DEFINITIONS:** **"You" or "Your":** - Means [Responding Party], including all agents, employees, representatives, attorneys, investigators, and any person acting on your behalf. **"Document":** - Means any written, recorded, or graphic matter, including emails, texts, letters, contracts, photographs, videos, electronic files, and social media posts. **"Identify" (when referring to a person):** - State full name, current address, telephone number, job title, and relationship to this case. **"Identify" (when referring to a document):** - State type, date, author, recipient, subject matter, and current location. **"Communication":** - Includes any transmission of information by any means, including oral, written, electronic, or otherwise. **"Incident":** - Refers to [specific event giving rise to this lawsuit]. **INSTRUCTIONS:** - Answer each request separately and fully - If objecting, state specific grounds - Produce documents within [30/45] days - Identify documents by Bates number if applicable - Update responses if new information discovered 3. **INTERROGATORIES (if applicable):** **Limit:** [Check jurisdiction - typically 25 in federal court] **INTERROGATORY NO. 1:** State your full name, all aliases, current address, date of birth, and Social Security number. **INTERROGATORY NO. 2:** Identify all persons with knowledge of facts relevant to this lawsuit, including their contact information and a brief description of their knowledge. **INTERROGATORY NO. 3:** Describe in detail your version of the events that led to this lawsuit, including dates, times, locations, and all persons present. **INTERROGATORY NO. 4:** Identify all documents that support your [claims/defenses] in this case. **INTERROGATORY NO. 5:** State the factual basis for each [claim/defense] asserted in your [complaint/answer]. **INTERROGATORY NO. 6:** Identify all expert witnesses you intend to call at trial, including their qualifications, opinions, and the basis for those opinions. **INTERROGATORY NO. 7:** Describe all injuries, damages, or losses you claim to have suffered, including the nature, extent, and duration of each. **INTERROGATORY NO. 8:** Identify all healthcare providers who have treated you for injuries related to this incident, including dates of treatment and diagnoses. **INTERROGATORY NO. 9:** State the total amount of damages you claim, itemized by category (medical expenses, lost wages, pain and suffering, etc.). **INTERROGATORY NO. 10:** Identify all insurance policies that may provide coverage for claims in this lawsuit. **[Continue with case-specific interrogatories based on discovery goals]** 4. **REQUESTS FOR PRODUCTION (if applicable):** **REQUEST NO. 1:** All documents and communications between you and [specific person/entity] concerning [specific topic]. **REQUEST NO. 2:** All contracts, agreements, or understandings between you and [party] relating to [subject matter]. **REQUEST NO. 3:** All photographs, videos, or audio recordings of [incident/location/person]. **REQUEST NO. 4:** All medical records, bills, and reports related to injuries claimed in this lawsuit. **REQUEST NO. 5:** All employment records, including pay stubs, tax returns, and personnel files, for the period [dates]. **REQUEST NO. 6:** All emails, text messages, and social media posts concerning [specific topic] from [date] to [date]. **REQUEST NO. 7:** All documents that support or contradict any statement made in your [complaint/answer/interrogatory responses]. **REQUEST NO. 8:** All insurance policies, declarations pages, and correspondence with insurers regarding this incident. **REQUEST NO. 9:** All expert reports, data, and materials relied upon by your expert witnesses. **REQUEST NO. 10:** All documents you intend to introduce as evidence at trial. **[Continue with case-specific document requests]** 5. **REQUESTS FOR ADMISSION (if applicable):** **Limit:** [Check jurisdiction - typically no limit but must be reasonable] **REQUEST FOR ADMISSION NO. 1:** Admit that you were the driver of the vehicle involved in the incident on [date]. **REQUEST FOR ADMISSION NO. 2:** Admit that the attached document marked as Exhibit A is a true and correct copy of the contract between the parties. **REQUEST FOR ADMISSION NO. 3:** Admit that you received written notice of [specific fact] on [date]. **REQUEST FOR ADMISSION NO. 4:** Admit that you failed to [perform specific obligation] as required by the contract. **REQUEST FOR ADMISSION NO. 5:** Admit that the statements attributed to you in Exhibit B are accurate. **REQUEST FOR ADMISSION NO. 6:** Admit that you have no evidence to support your claim that [specific allegation]. **REQUEST FOR ADMISSION NO. 7:** Admit that the fair market value of [property/services] was $[amount] on [date]. **REQUEST FOR ADMISSION NO. 8:** Admit that you were acting within the scope of your employment when [specific action occurred]. **[Continue with case-specific requests for admission]** 6. **Case-Specific Discovery:** **For Personal Injury Cases:** - Prior injuries or medical conditions - Accident scene details - Witness statements - Police reports - Insurance information - Medical treatment timeline - Lost wage calculations **For Contract Disputes:** - All contract drafts and amendments - Communications during negotiation - Performance records - Payment history - Breach notifications - Damages calculations - Mitigation efforts **For Employment Cases:** - Personnel file - Performance reviews - Disciplinary records - Comparator employee information - Company policies - Communications about termination - Severance negotiations 7. **Signature Block:** **Dated:** [Date] **Respectfully submitted,** [Your signature] [Your name] [Bar number] [Law firm] [Address] [Phone] [Email] **Attorney for [Your Client]** 8. **Certificate of Service:** **CERTIFICATE OF SERVICE** I hereby certify that on [date], I served a true and correct copy of the foregoing discovery requests upon all parties via [email/mail/hand delivery] to: [Opposing counsel name] [Address] [Email] [Your signature] [Your name] Provide discovery requests in a format that: - Complies with jurisdictional rules - Targets specific evidence needed - Anticipates common objections - Uses clear definitions - Avoids compound questions - Requests relevant documents precisely - Seeks meaningful admissions - Is ready to serve on opposing party