---
name: law-library-discovery
description: Research governing discovery rules and draft interrogatories, requests for production, or preservation plans anchored to retrieved authority and case elements.
---

# Discovery Research and Drafting

This file is usable as plain reading in a chat window. Use the court-rule, statute, and caselaw GET routes at https://implausible.enterprises/projects/law-library/for-llms.txt.

Before drafting, retrieve the governing discovery rules, numerical limits, proportionality standard, response deadlines, privilege rules, ESI and preservation authority, and applicable local rules or standing orders. Open the full rule text. Never state a limit or deadline from memory or a search snippet.

Map each proposed request to a claim element, defense, damages issue, witness/custodian, document category, system, or data source. Draft interrogatories, requests for production, and preservation demands as separate sections. Keep the requests usable; put legal analysis, sequencing strategy, and authority in a separate research note.

Use no more than three controlling procedural authorities at the top. Add substantive authorities only where they justify a specific disputed request or preservation duty. Surface privilege, proportionality, possession/custody/control, undue-burden, and ESI-format issues. List missing case facts and unsupported propositions explicitly.

Return a short strategy summary, controlling authority, the drafted requests, preservation scope, objections/risks to anticipate, and independent deadline verification steps.