First drafts of discovery requests ready for attorney markup
Drafting interrogatories and document requests from scratch is slow, and starting from a stale form means half the requests don't fit the case. Paralegals now prompt AI with the case facts to get a tailored first set, then refine it — vendors and practitioners report drafting time cut by half or more, with the attorney still reviewing and signing everything served.
You are assisting a litigation paralegal preparing a first draft of discovery for attorney review. Draft {{discovery_type}} in a {{case_type}} pending in {{jurisdiction}}. Facts and issues to cover (use only these): {{case_facts}} Output format: - Caption placeholder, then a short definitions and instructions section, then numbered requests. - Group requests by issue, most important first. - Make each request specific enough to survive an overbreadth objection — tie it to a party, time period, or event from my facts. - After the requests, add a "For attorney review" list: requests that may exceed local numerical limits, potential privilege issues, and facts I did not provide that would strengthen the set. Rules: - Do not invent facts, dates, parties, or events not in my summary. Where a detail is needed, write [CONFIRM: detail]. - Do not cite rules or case law from memory — write [CITE: rule] wherever authority belongs so we insert the verified rule text. - Put "DRAFT — FOR ATTORNEY REVIEW" at the top. - Plain, precise language. No "any and all" boilerplate chains.
Fill in your details and the prompt updates live — then copy.
DRAFT — FOR ATTORNEY REVIEW INTERROGATORY NO. 3: Identify every inspection of the loading dock ramp performed between January 2024 and the date of the incident, including the date, the person who performed it, and any written report generated. INTERROGATORY NO. 4: Describe every repair or modification made to the ramp surface after the complaint referenced in your incident log dated [CONFIRM: log entry date]. For attorney review: This set contains 22 interrogatories — check against [CITE: local rule] numerical limits. Interrogatory 9 may reach privileged post-incident investigation materials.
The full workflow
- Pull the facts from the complaint and case file, leaving out privileged material
- Run the prompt and resolve every [CONFIRM] flag from the file
- Replace every [CITE] flag with rule text verified in the actual local rules
- Route to the supervising attorney to revise, approve, and sign before service
Watch out for
UPL boundary: a paralegal cannot decide discovery strategy or serve discovery independently. The attorney must review, revise, and sign — AI speeds up the draft, it does not shorten the supervision chain (NALA Canon 1).
Case facts are confidential client information. Keep them out of consumer AI accounts that train on inputs; use your firm's approved tool and setting.
Never trust the model's memory of procedural rules. Verify numerical limits, response deadlines, and formatting against the current local rules yourself.
Where this comes from
Every use case on this site is grounded in real reports from working paralegals — not invented by us.