How to Draft Discovery Requests and Responses You Can Trust

This post details the technical process of grounding and verifying AI-generated discovery requests (interrogatories, requests for production, requests for admission) to ensure they are warranted, proportional, and not interposed for an improper purpose, as required by Rule 26(g). It explains how AI tools like Harvey can assist in drafting these requests by analyzing case records, governing law, and local rules, but emphasizes that the lawyer's reasonable inquiry and verification remain critical. The post highlights the importance of tying each request to specific claim or defense elements, grounding scope in the matter's record, and ensuring proportionality by considering case needs and resources. It also discusses how AI can help red-team these requests by identifying overbroad or compound questions before they are served.