Requests for Production Drafter
Early in discovery, when you know the claims and defenses and want a document request set that ties every request to an issue and will survive an overbreadth objection.
Requests for production are where most of the evidence in a civil case comes from, and they are also where most discovery fights start. Requests that are too vague invite boilerplate objections, requests that are too broad draw proportionality objections, and requests that never mention electronic form leave you with flattened PDFs and no metadata. A good set ties each request to a claim or defense and asks for documents the other side cannot credibly say it cannot find.
This prompt gives Claude the pleadings, your case notes and the relevant time period, then asks for definitions and instructions, form-of-production language for ESI under FRCP 34 or your state rule, and numbered requests grouped by claim or defense with the pleading paragraph quoted. It finishes with a proportionality table under FRCP 26(b)(1) that rates each request's overbreadth risk and offers narrower wording, so you can make those calls before service rather than after an objection.
The output is a drafting aid. You decide which requests serve the case strategy, confirm any limits on the number of requests, and check whether an ESI protocol or local rule controls the form of production. Review every request against the actual pleadings and the governing rules, and verify any authority you add, before the set is served.
The Prompt
I represent [PLAINTIFF/DEFENDANT], [CLIENT NAME], in [CASE NAME], a [CASE TYPE] matter in [COURT]. I need a first set of requests for production directed to [RESPONDING PARTY]. <pleadings> [PASTE THE COMPLAINT AND ANSWER, OR A SUMMARY OF CLAIMS AND DEFENSES] </pleadings> <case_notes> [KEY FACTS, KNOWN DOCUMENTS, LIKELY CUSTODIANS, SYSTEMS THE OTHER SIDE USES (EMAIL, CHAT, CRM, PHONES), AND ANY INTERROGATORIES ALREADY SERVED] </case_notes> Relevant time period: [START DATE] to [END DATE]. Governing rules: FRCP 34 or [STATE RULE]. Any limit on the number of requests: [LIMIT OR "NONE"]. Produce: 1. Definitions (only terms the requests actually use) and instructions, including a form-of-production instruction for ESI ([e.g., native format for spreadsheets; searchable images with load files and metadata fields [LIST FIELDS] for email]) and an instruction to log any documents withheld as privileged. 2. Numbered requests grouped by claim or defense. Head each group with the issue it targets and quote the pleading paragraph it ties to. 3. A proportionality table under FRCP 26(b)(1) or [STATE RULE]: Request No. | Issue targeted | Overbreadth risk (low, medium, high) | Why | Narrower alternative wording. Drafting rules: describe each category with reasonable particularity, avoid "any and all documents relating to" unless tied to a defined subject and date range, do not duplicate requests, and note where a request pairs with an interrogatory so I can coordinate them. Flag the facts you would need to tighten any request and anything in the notes you were unsure how to use. This is a draft for attorney review before service.
Example Output
Definitions and instructions with ESI form-of-production language, numbered requests grouped by claim or defense with pleading cites, and a proportionality table with narrower alternatives.
Illustrative example — names, figures, and facts are fictional.
FIRST REQUESTS FOR PRODUCTION (DRAFT): Pruitt v. Larkspur Health Services (fictional) Relevant period: January 1, 2023 to the present INSTRUCTION 6 (FORM OF PRODUCTION). Produce spreadsheets in native format. Produce email and attachments as searchable single-page images with load files and the following metadata fields: [FROM, TO, CC, BCC, DATE SENT, SUBJECT, CUSTODIAN, BEGBATES, ENDBATES]. GROUP A: RETALIATION CLAIM (Complaint ¶ 34: "Within two weeks of her complaint, Larkspur removed Plaintiff from the charge-nurse rotation.") RFP 1. All communications between [DEFINED MANAGERS] concerning Plaintiff's placement on the charge-nurse rotation from March 1, 2024 to June 30, 2024. RFP 2. The charge-nurse rotation schedules for Unit 4B from January 1, 2024 to December 31, 2024. Pairs with Interrogatory 5 (identify decision-makers). GROUP B: DEFENSE OF LEGITIMATE REASON (Answer, Fourth Defense: "Plaintiff was removed due to documented charting errors.") RFP 3. All documents reflecting charting errors attributed to Plaintiff, including audit reports. RFP 4. Charting audit reports for all charge nurses on Unit 4B for 2024, with patient identifiers redacted [CONFIRM PROTECTIVE ORDER]. PROPORTIONALITY CHECK RFP 1 | Retaliation causation | Low | Defined custodians and a four-month window | None needed RFP 4 | Comparator treatment | Medium | Covers all charge nurses for a full year | Limit to nurses supervised by [DEFINED MANAGERS] GAPS - The notes do not identify the chat platform Larkspur uses. Confirm before finalizing RFP 1. All names and facts are fictional and illustrative.
Tips
- •Name the other side's actual systems in the case notes (for example, the chat tool or the CRM); requests that name systems get better responses than generic 'electronic documents' language.
- •Use the proportionality table before service, not after the objections arrive. Swapping in the narrower wording now often avoids a meet-and-confer later.
- •Coordinate with interrogatory-drafter: ask the other side to identify documents in an interrogatory, then request them by category here.
- •Check local rules and any ESI order or protocol in the case; they may dictate the form of production and metadata fields.
- •Treat the set as a draft for attorney review and verify any rule you cite beyond the bracketed placeholders.
Frequently Asked Questions
Does the prompt handle ESI form of production?
Yes. It asks for a form-of-production instruction and lets you specify native production for spreadsheets and the metadata fields you want for email. FRCP 34 allows the requesting party to specify a form for electronically stored information. If the case has an ESI protocol or order, paste it into the case notes so the instruction matches it.
How does the proportionality check work?
Claude rates each request's overbreadth risk against the issues in the pleadings, explains the rating, and proposes narrower wording. The factors in FRCP 26(b)(1) include the importance of the issues at stake, the amount in controversy, the parties' relative access to relevant information, their resources, the importance of the discovery, and whether the burden outweighs the likely benefit. The table is a judgment aid; you decide which requests to narrow based on your strategy.
Can I use this in state court?
Yes. Replace FRCP 34 and 26(b)(1) with your state's rules in the placeholders. Many states model their discovery rules on the federal rules, but numbering, limits and proportionality language differ, so confirm the governing text yourself before you rely on any rule reference in the final set.
Should I serve all the requests Claude drafts?
Usually not. The draft is deliberately thorough so you can choose. Cut requests that duplicate others, that seek documents you already have, or that would draw a fight you do not need. A shorter, sharper set often produces better documents and fewer objections.
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