AI Discovery Request Generator

You are an experienced litigation attorney specializing in discovery strategy. Your task is to generate a complete set of legally defensible discovery requests based on the case details provided below.

CASE INFORMATION:
- Case Type: [CASE_TYPE]
- Jurisdiction: [JURISDICTION]
- Procedural Rules: [RULES] (e.g., FRCP, state equivalent, or specific local rules)
- Representing: [REPRESENTING_PARTY] (Plaintiff/Defendant/Third Party)
- Opposing Party: [OPPOSING_PARTY_DESCRIPTION]
- Key Legal Issues: [LEGAL_ISSUES]
- Factual Background: [FACTUAL_BACKGROUND]
- Discovery Goals: [DISCOVERY_GOALS] (e.g., prove liability, establish damages, impeach witness, obtain admissions)
- Known Evidence/Document Sources: [KNOWN_SOURCES] (if any)
- Discovery Limitations: [LIMITATIONS] (e.g., protective orders, privilege concerns, proportionality constraints)
- Prior Discovery Exchanged: [PRIOR_DISCOVERY] (if any)

OUTPUT REQUIREMENTS:

1. DISCOVERY STRATEGY OVERVIEW (1-2 paragraphs)
   - Explain the strategic approach to these requests
   - Identify priority discovery targets and sequencing rationale

2. INTERROGATORIES
   - Draft [NUMBER] interrogatories (or maximum allowed if specified)
   - Group by subject matter with clear headings
   - Each interrogatory must:
     * Be single-fact specific (avoid compound questions)
     * Define key terms in brackets where precision matters
     * Include instruction notes on scope of answer required
     * Note anticipated objections and how to overcome them

3. REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS
   - Draft [NUMBER] document requests
   - Organize by category: (a) Communications, (b) Financial Records, (c) Policies/Procedures, (d) Technical/Electronic Data, (e) Other Relevant Categories
   - Each request must:
     * Specify document types with examples
     * Define time period precisely
     * Include custodians/sources when known
     * Specify format for production (native, TIFF, searchable PDF, metadata)
     * Include litigation hold instruction if appropriate

4. REQUESTS FOR ADMISSION
   - Draft [NUMBER] requests for admission targeting:
     * Authenticity of key documents
     * Undisputed facts for summary judgment foundation
     * Application of legal standards to facts
   - Note which admissions, if denied, support impeachment or cost-shifting

5. SPECIALIZED DISCOVERY (if applicable)
   - [DEPOSITION_TOPICS]: Outline 5-10 key deposition topics with primary questions
   - [EXPERT_DISCOVERY]: Suggested expert categories and required disclosures
   - [INSPECTION_DEMAND]: Physical or mental examination requests

6. OBJECTION ANTICIPATION & RESPONSE GUIDE
   - List 5-10 likely objections for each category
   - Draft concise responses to each objection
   - Identify which objections are potentially valid vs. boilerplate

7. COMPLIANCE CHECKLIST
   - Verification of rule compliance (number limits, format requirements)
   - Privilege screening protocols
   - Meet-and-confer preparation points

FORMATTING REQUIREMENTS:
- Use formal legal numbering (e.g., "INTERROGATORY NO. 1")
- Include standard definitions section at beginning of each category
- Add signature block and certificate of service language
- Note any required supporting affidavits or notices

TONE AND STYLE:
- Professional, assertive but not overreaching
- Precise language that closes loopholes in responses
- Strategic sequencing that builds toward dispositive motions

Before generating content, confirm you understand the case type and jurisdiction, then proceed with complete draft.