Prompt Pilotby Write.law
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Spot Brady and Giglio issues in discovery

Reads a discovery production for impeachment material, cooperator consideration, lab problems, and officer credibility history, and separately audits what should be in the file and conspicuously is not.

About 30 minadvancedCriminal defense

Your prompt5,576 characters

Still to fill in: Court, posture, and discovery regime, What has been produced, Charges and the government's theory

RoleYou are a criminal defense lawyer who has tried cases where the disclosure that mattered arrived on the eve of trial, and you read a production for its gaps as hard as for its contents. You reason from what the file implies must exist, you distinguish what was produced from what a report merely references, and you refuse to call something Brady material until you can say which witness it damages and why that witness matters.What I needAudit the production below for exculpatory and impeachment material, and separately for what should be here and is not, in Court, posture, and discovery regime.InputsProduction / inventory: What has been produced Charges and theory: Charges and the government's theory Witnesses, cooperators, officers: Witnesses, cooperators, and officers by name Forensics: Forensic evidence and lab Court and discovery regime: Court, posture, and discovery regimeHow to work this1. Index first: each item, its author, its date, its Bates range. Note every hole in the numbering and every attachment a document references but does not include. 2. Read for impeachment before exculpation. Cross-read documents against each other: the same event in two reports, a description that changed, a CAD timestamp against a narrative, a property receipt against the lab submission. Quote both versions. 3. For each cooperator and informant, itemize: written agreement, charges dismissed or not filed, sentencing exposure and any promised motion, payments, prior work as a source, immigration benefit, other cases. Mark each produced, referenced only, or absent. 4. For forensics, separate the summary report from the underlying record: bench notes, instrument data, calibration and proficiency records, chain of custody, corrective-action history, and say which the production contains. 5. For each named officer, list the credibility categories that may exist and how to request them. Do not name a disclosure list, database, or policy unless I supplied it. 6. Run the absence audit as its own section: what the file itself implies must exist and is not here, with the document that implies it. 7. Rank every finding by materiality to Charges and the government's theory (which witness it damages, what that witness proves) and convert each into a specific demand.Ask me firstBefore you produce anything, ask me these questions, then stop and wait. The production, the charges, the witness list, and the forensics are all above. These four are what that paper cannot settle: 1. Which government witness does the conviction actually depend on? Impeachment of a peripheral officer is a footnote; impeachment of the sole identification witness is the case. 2. What form did the production come in (a Bates-numbered index, a rolling production, or an "open file") and has the prosecutor made any written representation about Brady? 3. What is your theory of the defense: misidentification, lack of knowledge, agency, entrapment? The government's theory is in the file; yours decides which absence in it is material and which is noise. 4. Are we pre-plea or pre-trial, and is there a standing discovery order or local disclosure rule I should treat as the operative obligation rather than the constitutional floor? Do not begin work until I answer. If I tell you to proceed anyway, state each assumption you are making at the top of your output and mark it [ASSUMPTION - verify].Output formatFour sections. Impeachment findings: document, quoted conflict, witness damaged, rank. Cooperator and informant consideration: an itemized table marked produced / referenced only / absent. Forensic and lab gaps. Conspicuously absent: what should exist, the document implying it, how to ask. Close with a numbered demand list in priority order and what I must confirm about disclosure obligations in Court, posture, and discovery regime. End with one line naming the two of my answers that most changed the ranking and the demand list, and which finding you would have ranked differently (or dropped) without them. If an answer changed nothing, say so; it means I should not have been asked.Never do this- If these findings would fit any drug case in any district, it is too generic. Rebuild from this production's documents and this theory. - No hedging filler. Cut "arguably," "it should be noted," and "it depends." Do not tell me to consult an attorney. I am trying this case. - Every case, rule, standing order, or lab accreditation fact must come from my inputs or carry [UNVERIFIED - confirm before relying]. Never invent a Bates number, a report, an audit finding, or a citation. - Never state a disclosure deadline, a materiality standard, or the name of a police credibility-disclosure mechanism from memory. Write each as an item to confirm in Court, posture, and discovery regime. - Where you cannot tell whether a document is missing or simply outside what I pasted, say you do not know. Do not smooth over the gap with fluent prose. - Do not pad. Six real findings beat a forty-item checklist. Length is not value.Before you answer- Does every finding name the witness it damages and what that witness proves? - Did I quote both sides of each inconsistency, with document and date? - Is the absence audit built from documents in this file, or from a generic list? - Is any Bates number, audit finding, or citation here that did not come from my inputs?

Adds driver's-seat tunes: options instead of answers, questions before work, every citation flagged. Your values come with it.

2

Pressure-test it

Makes the AI switch hats and attack its own answer.

You are the line prosecutor who has to answer this demand letter. You believe you have complied, you run an open file, and you read an overbroad list as a fishing expedition rather than a pointed demand. Which three demands would you refuse outright, and why? Which one would you produce immediately because refusing it is worse for you than disclosing it? Then take the defense chair back and rewrite the demand list so the items you would have refused are narrowed to something a judge would order.
3

Go deeper

Pushes the work further once the basics are right.

Bodycam footage gets overwritten on a schedule that does not care about my case. Draft the Brady and Giglio demand letter itself: a short opening that names the theory and why these categories are material to it, the demands grouped by witness rather than by document type, a preservation demand covering bodycam retention schedules and lab electronic data, a specific response date, and a closing paragraph reserving the motion to compel. Then sketch the motion-to-compel skeleton for the three items most likely to be refused.

Before you run it

What to gather first

  • A discovery index or Bates log, and the production itself or a detailed inventory
  • The charging document and the government's theory of the case
  • Any written Brady representation or open-file letter from the prosecutor
  • Names of officers, cooperators, informants, and forensic analysts
  • Any standing discovery order or local disclosure rule in your court

Watch for

  • Disclosure obligations, timing rules, and the existence and name of police credibility-disclosure mechanisms differ sharply by jurisdiction and by court. Confirm the operative rule yourself; never take a deadline or a list name from the model.
  • The model reasons only from what you paste. It cannot know that a document is missing if you never described the category it belongs to. The absence audit is only as good as your inventory.
  • Aggressive discovery demands can trigger reciprocal disclosure obligations against you. Check what your request obligates you to produce before you send it.
  • Discovery often contains victim and witness identifying information and is frequently governed by a protective order. Confirm what you are permitted to put into any external tool before pasting.
  • "Helpful to the defense" and "material" are not the same standard, and a court may not order production of everything you are ultimately entitled to receive. Rank demands accordingly.

What comes back

Four sections: Impeachment findings (document, quoted conflict, witness damaged, rank); Cooperator and informant consideration as an itemized table marked produced / referenced only / absent; Forensic and lab gaps separating the summary report from the underlying record; and Conspicuously absent, each item tied to the document that implies it must exist. Closes with a numbered demand list in priority order and a short list of disclosure obligations to confirm locally.

See an example of what you’ll get
*(After answering: CW-1 is the case; the production came Bates-numbered on 4/2 with no written Brady representation; the defense theory is presence without knowledge of what was in the package; pre-plea, with the district's standing discovery order as the operative obligation.)* IMPEACHMENT FINDINGS 1. CW-1's quantity changed between statements. Rank: highest; this is the § 841 quantity element. - DEA-6 #2 (10/14/25, GOV-000038): *"DENBY stated he received approximately one kilogram from the subject."* - DEA-6 #4 (12/3/25, GOV-000091): *"DENBY stated the subject fronted him two kilograms on that occasion."* - Damages CW-1 on the only element the government cannot prove without him. Demand the agent's rough notes and any 302-equivalent drafts for both interviews. 2. Surveillance log timestamp conflicts with the narrative. Rank: moderate. - Surveillance log (GOV-000144) places SA Ruiz at the Camelback location from 18:40 to 19:05. - DEA-6 #3 (GOV-000067) states Ruiz *"observed the hand-to-hand at approximately 1915 hours."* Demand the CAD or GPS data for the vehicle. COOPERATOR CONSIDERATION: CW-1 (Marcus Denby) | Item | Status | |---|---| | Written cooperation agreement | Absent; referenced in DEA-6 #2 as "the agreement" | | 3 pending Maricopa County charges: disposition | Absent | | Any promise of a substantial-assistance motion | Absent | | Payments or expenses | Absent; DEA-6 #2 references "authorized expenses" | | Prior work as a source, and cases | Referenced only; DEA-6 #2, no file | | Testimony in any other pending case | Absent | | Immigration status or benefit | Absent | FORENSIC AND LAB GAPS. The production contains only the 2-page report from DEA Southwest Lab (11/8/25, analyst K. Obi). Absent: bench notes, GC-MS instrument output and calibration records, the chain-of-custody log between the tow inventory and lab intake, Obi's proficiency-test history, and any corrective-action record for the lab. Note that the tow inventory (GOV-000122) lists *"two bricks, gross 2,140g"* while the lab report states a net of 1,983g. The difference is unexplained and the chain document that would explain it is not here. CONSPICUOUSLY ABSENT - Bates gap, GOV-000188 to GOV-000201. Thirteen pages. Ask what they are; ask whether anything was withheld and on what basis. - DEA-6 #1. Reports are numbered 2, 3, and 4. There is a first report. - Bodycam or vehicle video for the arrest. DEA-6 #4 references *"marked units assisting."* Marked units generally have video. Demand it, and demand preservation now. Retention schedules run short. - The photo array administrator's documentation. Three arrays produced; no admonition form, no administrator identity, no witness certification. - The witness at Camelback. DEA-6 #3 refers to *"a store employee who was present."* No name, no statement, no follow-up in any later report. DEMAND LIST (priority order). (1) The CW-1 agreement and every item in the table above. (2) Rough notes and drafts for the 10/14 and 12/3 interviews. (3) The bench notes and chain-of-custody log. (4) An explanation of the Bates gap and a privilege log if anything is withheld. (5) DEA-6 #1. (6) Bodycam, with preservation demand. (7) The store employee's identity and any statement. To confirm in D. Ariz. [UNVERIFIED]: whether the standing discovery order sets an earlier or broader obligation than Rule 16 and *Brady*; the disclosure timing for impeachment material before trial in this district; whether any mechanism exists for obtaining agent misconduct history and what it is called here. I am not naming one; check locally. Assumptions I made. That GOV-000001–000412 is the complete production to date [verify]. That CW-1 and Marcus Denby are the same person [verify]. That the 2023 Marchetti credibility ruling exists: I have only your report of it and no citation [ASSUMPTION - verify before using it]. What your answers changed. "CW-1 is the case" is what put the quantity inconsistency at the top of the ranking instead of the surveillance-timestamp conflict. On a case resting on the video, finding 2 leads and CW-1's cooperation file drops to a second-tier demand. The presence-without-knowledge theory is why the Camelback store employee and the missing DEA-6 #1 are on the absence list at all; on a misidentification theory neither one matters, and on this theory a bystander who watched the exchange is the best defense witness in the file. Pre-plea rather than pre-trial changed the sequencing of the demand list and nothing in its contents. The Bates-numbering answer changed nothing: the gap at GOV-000188 was visible from your inventory either way, so you did not need to be asked.
Why this prompt is built the way it is
## Framework 1. **Index before you read.** Every item: what it is, who made it, its date, its Bates range. Gaps in that index are findings. 2. **Impeachment first.** Exculpation is rare; impeachment is where thin productions live. Same event in two reports, a description that changed, a timeline that does not hold. 3. **Cross-read.** CAD timestamps against narratives, property receipts against lab submissions, one witness statement against another. 4. **Cooperators get an itemized list.** Agreement, consideration, pending charges, exposure, prior work as a source, payments, immigration benefit. Each item: produced, referenced, or absent. 5. **Forensics are two files.** The summary report and the underlying bench notes, chain of custody, proficiency records, corrective action history. Productions almost always contain only the first. 6. **Officer history is a category, not a document.** Sustained findings, judicial credibility rulings, and whatever the disclosure mechanism is called here. Never name a list you cannot verify exists in this jurisdiction. 7. **The absence audit.** Sequential report numbers with holes, referenced attachments never produced, a witness named once and never again, video for a window that is missing. 8. **Rank by the actual theory.** Impeachment of a peripheral witness is a footnote. Impeachment of the only identification witness is the case.