Discovery Response Generator

When responding to any set of written discovery — interrogatories, requests for production, or requests for admission.

Draft responses to the following discovery requests:

Case type: [TYPE]
Your client's role: [PLAINTIFF/DEFENDANT]
Applicable rules: [FRCP / STATE RULES]
Response deadline: [DATE]

For each request:
1. State appropriate objections (if any):
   - Overbroad, unduly burdensome, not proportional to the needs of the case
   - Vague or ambiguous terms
   - Attorney-client privilege or work product
   - Seeks information not relevant to claims or defenses
2. Subject to and without waiving objections, provide a substantive response
3. For document requests: identify responsive documents by category or Bates range
4. For interrogatories: provide factual answers with appropriate qualifications

IMPORTANT:
- Preserve all objections even when providing a response
- Use "Subject to and without waiving the foregoing objections" before substantive responses
- Never waive privilege by describing privileged communications
- Include a general objection section at the top

Discovery requests:
[PASTE REQUESTS]

Available information for responses:
[DESCRIBE WHAT YOU KNOW AND WHAT DOCUMENTS EXIST]

Example Output

A formatted set of responses with objections, substantive answers, and privilege preservations for each request.

Tips

• •Always include boilerplate objections even for straightforward requests — they preserve your rights.
• •Respond with the information you have now, and supplement later if you discover more.
• •Coordinate document production numbering (Bates stamps) with your responses.

Related Prompts