This page lists three turns, the messages you send to the AI one after another in the same chat, and then a check of the answer. Keep it open next to your chat. Each turn shows the next thing to paste, with the values you entered already filled in. Nothing is sent from this page, and your conversation stays in the AI tool you are using.
The claims, the defenses, and the theory each side is running.
Determines which elements you must prove and which you only need to defeat.
The specific holes in your record: not topics, but the facts you need and do not have.
The court and the numbers that bind you: interrogatory caps, local rules, any ESI protocol or standing order.
Who and what you believe holds the evidence.
Controls sequencing and whether contention interrogatories belong in this set.
Watch for these throughout
Numerical limits bind, and discrete subparts count. Confirm the cap on interrogatories and requests in the local rules and the standing order before serving.
If an ESI protocol is in place, its format, metadata, and search-term provisions override anything drafted here. Read it first.
Requests aimed at in-house counsel custodians, ephemeral messaging, or personal devices will trigger privilege and possession-custody-control fights. Plan the sequence and the fallback before serving.
A precise request set tells the other side exactly what your theory is. Decide what you are willing to reveal in exchange for what you need.
The model will confidently name systems, custodians, job titles, and retention practices that do not exist at this company. Verify every proper noun before service.