Lawyers

Discovery Request Builder

Generate comprehensive discovery requests — interrogatories, requests for production, and requests for admission — tailored to the specific claims and defenses in your case. Effective discovery requests are the foundation of successful litigation; this prompt helps you build thorough, targeted requests that expose the evidence you need.

Generates comprehensive, formatted discovery requests — interrogatories, requests for production, requests for admission, or all three — tailored to the specified claims, defenses, and evidence needs in the described case, with a definitions section and appropriately scoped request language calibrated to the specified jurisdiction's discovery rules and limits. The output is a complete first-draft request set the attorney reviews and narrows against the opponent's likely objection strategy before serving. Designed for commercial litigators who need to build thorough, targeted discovery requests without starting from scratch — particularly useful at the early-discovery stage when the attorney knows what evidence is needed but has not yet committed to a deposition strategy.

Testedclaude-sonnet-4-6ValidatedMar 2026ScopeThis is informational only, not legal advice. Recommend cons…TierAdvanced
AI Role
You are a senior litigation attorney with 15+ years of experience in complex com…
Models
Claude
Confidence
Advanced
Constraints
This is informational only, not legal advice. Recommend consulting a licensed attorney for specific matters.
Discovery request limits and objection standards vary by jurisdiction — verify applicable rules before serving.
Overbroad or abusive discovery requests may result in sanctions — attorney review is required before serving.
ESI discovery has specific protocol requirements (FRCP 26(f) conference, proportionality standards) — ensure compliance with applicable rules.
Tested Models
claude-sonnet-4-6
Uncertainty
If information is ambiguous, incomplete, or the legal question falls outside the specified scope, clearly state your assumptions and recommend professional legal review.
Jurisdiction
US-general
Last updated
2026-05-28 — Published

The prompt

1,784 characters
discovery-request-builder.prompt
You are a senior litigation attorney with 15+ years of experience in complex commercial litigation and discovery strategy.

Generate discovery requests for the following case:

Case Type: [TYPE OF CASE — e.g., 'Breach of contract — commercial lease', 'Employment discrimination', 'Business tort']
Discovery Target: [WHO THESE REQUESTS ARE SENT TO — plaintiff, defendant, specific party]
Claims/Defenses at Issue: [LIST THE ACTIVE CLAIMS AND DEFENSES]
Key Facts in Dispute: [WHAT FACTS ARE ACTUALLY CONTESTED]
Evidence You Need: [DESCRIBE WHAT YOU ARE LOOKING FOR — types of documents, information about events, admissions you want]
Discovery Format Requested: [INTERROGATORIES / REQUESTS FOR PRODUCTION / REQUESTS FOR ADMISSION / ALL THREE]
Jurisdiction and Rules: [APPLICABLE RULES — e.g., 'FRCP', 'California CCP', specify court rules if relevant]
Case Stage: [WHEN IN THE CASE — e.g., 'Early discovery', 'Expert phase', 'Pre-trial']

For each discovery format requested, generate:

### Interrogatories (if requested)
Numbered interrogatories with definitions section, using proper format for the specified rules. Include: identity interrogatories, factual basis interrogatories, damages interrogatories, and expert interrogatories as appropriate.

### Requests for Production (if requested)
Numbered requests with definitions section. Cover: documents supporting claims/defenses, communications, records, ESI (electronically stored information), and third-party documents.

### Requests for Admission (if requested)
Numbered requests designed to authenticate documents, admit undisputed facts, and narrow the issues for trial.

Note limits under the applicable rules (e.g., 25 interrogatory limit under FRCP 33) and flag where you may need to request leave for additional requests.
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How to use this prompt

1

1. Specify the claims and defenses clearly — discovery should map directly to the elements you need to prove or disprove.

2

2. Describe the evidence you need rather than just the discovery format — the AI will translate your evidence needs into appropriate request language.

3

3. Review the output against your jurisdiction's discovery rules before serving, particularly interrogatory limits and ESI protocols.

Customization tips

Add 'Include a litigation hold notice template' to accompany the first round of discovery requests.
Specify 'Focus on ESI — include protocol for metadata preservation and search term negotiation' for document-intensive matters.
Add 'Include contention interrogatories for each affirmative defense' to lock opposing counsel into their theory early.
For damages-focused discovery, add 'Include detailed damages interrogatories covering all categories of claimed losses and their calculation methodology.'

Sample output

Mar 2026Advanced
PLAINTIFF'S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS IN THE MATTER OF: DataVantage Analytics, Inc. v. [Defendant] CASE NO.: [TBD] Pursuant to applicable civil procedure rules, Plaintiff DataVantage Analytics, Inc. requests that Defendant produce the following documents within 30 days of service: DEFINITIONS: "Joint Venture Period" means March 2024 through January 31, 2026. "Proprietary Training Data" means any dataset, data file, or compilation provided by DataVantage to Defendant during the Joint Venture Period. "Analytics Module" means any data analytics software product or feature developed or released by Defendant after January 1, 2026. DOCUMENT REQUESTS: REQUEST NO. 1: All documents relating to Defendant's retention, storage, backup, or archiving of DataVantage's Proprietary Training Data after January 31, 2026. REQUEST NO. 2: All documents relating to the development of Defendant's Analytics Module, including design specifications, architecture documents, model training logs, and data source documentation. REQUEST NO. 3: All internal communications (email, Slack, Teams, or other messaging platforms) discussing the Proprietary Training Data after the joint venture termination date. REQUEST NO. 4: All communications between Defendant and any third party regarding the source or composition of the training data used in Defendant's Analytics Module. REQUEST NO. 5: All vendor agreements, data licensing agreements, or data purchase agreements entered into by Defendant between January 1, 2025 and the present relating to AI training data. REQUEST NO. 6: All documents constituting or evidencing Defendant's return or destruction of DataVantage's Proprietary Training Data, including any certification or acknowledgment. REQUEST NO. 7: All technical documentation, including model cards, training logs, and evaluation reports, for any machine learning model trained during or after the Joint Venture Period. REQUEST NO. 8: All board, executive, or management presentations discussing the joint venture dissolution, the Proprietary Training Data, or the development of the Analytics Module. Note: These discovery requests are a framework for attorney review. Adapt to the specific facts, governing procedural rules, and court requirements. This does not constitute legal advice.

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Frequently asked questions

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Professional Disclaimer

This AI-generated content is for informational and educational purposes only. It does not constitute legal advice and should not be relied upon as such. Always consult a licensed attorney for specific legal matters.