Draft

Answer discovery without the boilerplate

Reads what each request actually asks before objecting to it, replaces reflexive objections with ones tied to the request's real defect, states what is being withheld, and writes the narrowing you would accept.

About 25 minintermediateLitigation

Your prompt6,385 characters

Still to fill in: The requests as served, What the case is about, Court and any protocol, Who you represent

RoleYou are a litigator who has been on both ends of a motion to compel and learned which objections a magistrate reads and which ones make them stop reading. You restate what a request actually asks before you object to it, you never write "overbroad and unduly burdensome" without saying broad as to what and burdensome how, and you say what you are withholding, because silence about what is withheld is where the sanctions live.What I needDraft responses and objections for Who you represent to the requests below, in Court and any protocol.InputsRequests as served: The requests as served What the case is about: What the case is about Court and protocol: Court and any protocol Who I represent: Who you represent What the client actually has: What the client actually hasHow to work this1. For every request, restate in one line what it actually asks for, reading the definitions and instructions as part of it. A response drafted from the objection outward answers a request nobody served, and the definitions section is usually where the real scope problem lives. 2. Sort every request into exactly one of four: answer in full; answer as narrowed, with the narrowing stated in the response itself so the other side knows precisely what they are getting; object and produce nothing, with the basis; or cannot answer without more from the client, with what is needed. 3. Make every objection specific to this request's actual defect. If it is overbroad, say broad as to what: a time period beyond the conduct in What the case is about, custodians with no connection, or subject matter outside the claims. If it is burdensome, say how: the volume, the system it would have to come from, whether that system is searchable, and what the collection would involve. An objection that does not name the defect is the objection that gets a motion granted against you. 4. State what is being withheld under each objection. A response that objects and then produces something without saying what was held back is the pattern magistrates sanction, and it is invisible until somebody asks. 5. Handle privilege and work product separately from the substantive objections, and say for each request whether a log entry will be generated and roughly what category it covers. 6. Work the specific traps in this set: a request for "all documents" with no time limitation; a defined term whose definition expands the request well past its own words; a document request that is really an interrogatory; a request calling for a legal conclusion or for the application of law to fact; and a request built on a characterization Who you represent contests, where answering adopts the characterization. 7. For every request you object to or narrow, give the position you would take in a meet and confer: what you will produce if they narrow, and to what. Write it so the letter is already half drafted.Close with these four sections, every time, without being askedAssumptions I made. Every assumption about what Who you represent has, what a system can do, and what a definition was meant to reach. Mark each [verify] or [safe]. Where I assumed a burden without knowing the volume, say so, because an unquantified burden objection is the one that fails. Where this is weakest. The two or three objections most likely to be overruled, named by request number, with the reason a magistrate would give. What only you can decide. Options with tradeoffs, never a bare flag. At minimum: which fights to take. Objecting to a request you will eventually have to answer buys a few weeks and costs credibility on the objections that are genuinely good, while producing broadly on the marginal requests concentrates the dispute on the two or three where you are strongest. Also yours: whether to volunteer a narrowing in the response itself, which is efficient and reveals where your own line is before the other side has to argue for it. What would make this materially better. Ranked: actual volume and hit counts from the systems, the ESI protocol text, confirmation of which custodians exist and what they use, and the scheduling order so the narrowing can be sized to the time remaining.Output formatResponses in filing form, request by request. Each carries: the one-line restatement, the objections with their specific defects named, the statement of what is being withheld, and the response itself with any narrowing stated in it. Then a summary table: Request | Sort | Objection basis | Withholding | Meet-and-confer position. Then the privilege and log note. Then the traps found in this set, by request number. Then the four sections.Never do this- If the objections would fit any discovery set in any case, they are too generic. Every objection names what is broad and how it is burdensome, in this case's own terms. - No hedging filler. "Defendant objects to the extent this request may be overbroad" objects to nothing. Object or do not. Do not tell me to consult an attorney; I am the attorney signing these. - Never state a rule number, a proportionality standard, a response deadline, or what Court and any protocol requires an objection to contain. Mark each [CONFIRM] and cite nothing. Never invent a citation, a case, or a quotation from the requests. Never assert a volume, a hit count, or a system capability that What the client actually has does not supply; anything you cannot source is marked [UNVERIFIED - confirm with the client]. - Where you cannot tell whether the client has responsive material, say you do not know and put the request in the fourth sort rather than drafting an objection that assumes a burden. - Do not pad. A request that should simply be answered gets a one-line response. Length is not value.Before you answer- Does every objection name what is broad and how it is burdensome, in specifics? - Does every objected request state what is being withheld under it? - Did I restate each request before responding, and did any restatement differ from what I then answered? - Did I assert a volume, a cost, or a system limitation that was not in my inputs? - Would these responses be useless in a different case? They should be.

The run walks turn one, the pressure test, the follow-up, and a check on what came back. The Cockpit adds driver's-seat tunes. Your values come with either one.

Pressure-test it

Makes the AI switch hats and attack its own answer.

Your responses go up as an exhibit to a motion to compel. Read them as the magistrate deciding it, with the requests in one hand and the responses in the other: which objection would you overrule without argument, which response tells you nothing about whether anything was withheld, and which narrowing looks like a concession the responding party has already made and should be held to? Then tell me the two responses I amend before the meet and confer rather than after the ruling.

Go deeper

Pushes the work further once the basics are right.

Responses create obligations somebody at the client has to actually meet. Build the collection plan behind them: for every request answered in full or as narrowed, the custodians, the systems, the date range, the search terms if the protocol sets them, who at the client pulls each piece, and the date it has to be back so these responses do not become promises nobody kept.

4Check what came backPaste the answer here and work a checklist against this prompt's own rules.

Before you run it

What to gather first

The requests exactly as served, with the definitions and instructions
What the case is actually about, so relevance objections mean something
What documents and systems your client actually has
The forum, since proportionality practice and objection rules differ
Anything already produced or agreed in an ESI protocol

Watch for

Boilerplate objections have drawn sanctions and waiver findings in many courts. An objection that does not state its grounds with specificity can forfeit the objection entirely.
Failing to state what is being withheld under an objection is its own violation in many forums, separate from the objection's merits.
The model cannot know your client's data volumes or system capabilities. Every burden objection has to be backed by a number somebody at the client provides.
Proportionality practice, the form of objections, and response deadlines vary by forum and by judge. Confirm each before serving.
Do not paste privileged material or client-confidential documents. The requests and a description of the client's systems are enough to draft from.

What comes back

Responses in filing form request by request, each with the one-line restatement, specific objections naming the defect, a statement of what is withheld, and the response with any narrowing stated in it. Then a summary table (request, sort, objection basis, withholding, meet-and-confer position), a privilege and log note, the traps found by request number, and the four closing sections.

See an example of what you’ll get

RESPONSE TO REQUEST NO. 4 *What it asks:* All documents concerning any employee who left to join a competitor, with no time limitation, and with "competitor" left undefined. *Objections.* Northline objects that this request is overbroad as to time, because it has no limitation and the conduct at issue in this case runs from January 2025 to August 2025. Overbroad as to subject matter, because it reaches employees with no connection to the trade secret claim or to Reyes. And undefined, because "competitor" appears nowhere in the definitions and Northline cannot determine which departures are covered. Northline further objects that the request is burdensome as to system: pre-2023 personnel records sit on a legacy file server with no search capability, and responsive material there could only be located by manual review of individual folders. *What is withheld.* Subject to and without waiving these objections, Northline is withholding documents concerning departures outside January 2025 to August 2025 and departures of employees outside the Engineering organisation. *Response.* Northline will produce non-privileged documents concerning the departure of any Engineering employee between January 1, 2025 and August 31, 2025 who joined a company identified in Plaintiff's Interrogatory No. 2, located through the custodians and search terms set by the ESI protocol. RESPONSE TO REQUEST NO. 11 *What it asks:* All documents supporting Northline's contention that Reyes did not misappropriate the customer list. *Objections.* Northline objects that this request calls for the application of law to fact and effectively asks Northline to marshal its defense, which is the subject of contention interrogatories rather than a document request. Northline further objects that it calls for attorney work product to the extent it asks which documents counsel has selected as supporting a contention. *What is withheld.* Northline is withholding no documents on the basis of these objections other than counsel's selection and compilation of documents, which will not be logged individually. *Response.* Northline will produce the non-privileged documents responsive to Requests 5 through 9, which encompass the factual material bearing on this issue. Summary | Req | Sort | Objection basis | Withholding | Meet-and-confer position | |---|---|---|---|---| | 1 to 3 | Answer in full | None | None | Not in dispute | | 4 | Answer as narrowed | Time, subject matter, undefined term, system burden | Departures outside the window and outside Engineering | Will extend to Sales if they define "competitor" and accept the same date range | | 5 to 9 | Answer in full | None | None | Not in dispute | | 10 | Cannot answer yet | Not applicable | Unknown | Need to know whether Slack data within retention exists for these custodians | | 11 | Object, produce via others | Application of law to fact; work product | Counsel's selection only | Will answer a properly framed contention interrogatory | | 14 | Answer as narrowed | Built on a contested characterization | Nothing | Will produce, with a statement that production does not adopt the term "the Stolen List" | Privilege and log. Requests 5 through 9 and 14 will generate log entries covering communications with in-house and outside counsel after the February hold notice. Request 11 generates no individual entries beyond the work product objection above. [CONFIRM - whether this court requires post-complaint communications with counsel to be logged at all.] Traps in this set. Request 4 has no time limit and an undefined term, which is the cleanest objection on the list. Request 11 is an interrogatory wearing a document request's clothes. Request 14 uses the defined term "the Stolen List," and answering it without saying otherwise adopts the characterization. Requests 16 and 17 rely on a definition of "Confidential Information" in the instructions that is broader than the definition in the parties' own agreement, which is a scope problem hiding in the definitions rather than in the requests. --- Assumptions I made. That the legacy file server genuinely has no search capability [verify: this carries the burden objection to Request 4, and an unquantified burden objection is the one that fails]. That the ESI protocol sets custodians and terms that cover Engineering [verify against the protocol text]. That Slack retention is 90 days and that the relevant period is outside it [verify: if any of it is inside retention, Request 10 changes from unanswerable to answerable]. Where this is weakest. The subject-matter objection to Request 4 will be the first thing challenged, because a trade secret plaintiff will argue that departures outside Engineering are exactly where a pattern would show. Expect to lose the Engineering limitation and keep the date range. Second, the work product objection to Request 11 is correct and is stated in a way that sounds like a refusal to produce documents rather than a refusal to categorise them; a magistrate skimming will read it the second way. What only you can decide. Which fights to take. Objecting to Requests 16 and 17 on the definitions problem is a good objection and it costs a meet and confer on a set where you are already narrowing four requests; producing on them concentrates the dispute on Request 4, where you are strongest. Second call that is yours: whether to state the Request 4 narrowing in the response itself. Stating it is efficient, is well received, and tells the other side exactly where your line is before they have argued for anything. What would make this materially better. Ranked by impact: (1) Volume and hit counts from the legacy server, which turn the Request 4 burden objection from an assertion into a fact. (2) The ESI protocol text. (3) A custodian list with what each of them actually uses, which decides Request 10. (4) The parties' agreement's definition of Confidential Information, so the Requests 16 and 17 objection can quote the mismatch.

Why this prompt is built the way it is

## Framework 1. **Restate the request in one line before objecting to anything.** Drafting from the objection outward answers a request nobody made. 2. **Four sorts:** answer in full; answer as narrowed with the narrowing stated; object and withhold with the basis; cannot answer without more from the client. 3. **Every objection names the defect:** broad as to time, custodians, or subject matter, and burdensome in volume, systems, or cost. Otherwise do not make it. 4. **State what is being withheld** under each objection. 5. **Handle privilege and work product separately,** and say what goes on the log. 6. **Work the traps:** no time limit, a definition that expands the request, an interrogatory in disguise, a request for a legal conclusion, a request built on a contested term. 7. **Give the narrowing you would accept,** so the meet-and-confer letter writes itself.