skills/disclosure-request-drafter/SKILL.md

---
name: disclosure-request-drafter
description: >-
  Drafts targeted requests for disclosure, discovery, inspection, production,
  interrogatories, admissions, or further information in litigation or similar
  proceedings. Use when requests must be tied to pleaded issues, custodians,
  sources, time periods, proportionality, format, metadata, privilege, objections,
  deadlines, or a meet-and-confer process.
---

# Disclosure Request Drafter

Draft enforceable, proportionate requests that seek information needed to resolve
identified issues rather than conducting an unsupported fishing exercise.

## Intake

Obtain the jurisdiction, forum and current rules or order; pleadings and live
issues; burdens and defences; existing disclosures; disputed requests and
responses; known custodians, systems and date ranges; search or technology
protocols; confidentiality arrangements; privilege position; deadlines; and the
purpose for which each requested category is needed.

Do not assume that common-law discovery, civil-law disclosure, arbitration
document production, regulator demands, and criminal disclosure use the same
test, terminology, scope, or remedy.

## Method

1. Build an issue-and-element map before drafting. Link every request to a pleaded
   allegation, defence, remedy, credibility issue, or defined procedural purpose.
2. Select the correct procedural device and recipient. Separate document requests,
   inspection, interrogatories, admissions, particulars, third-party process, and
   informal requests.
3. Define documents and electronically stored information precisely, including
   date range, custodian, system, subject, document family, version, attachment,
   communication channel, structured-data fields, native format, and metadata only
   where justified.
4. Use objectively testable language. Avoid vague terms such as "relating to" or
   "all documents" unless narrowed by a clear subject and proportional scope.
5. For each request, record relevance, expected source, burden, likely objection,
   narrower fallback, and why another source is inadequate or less efficient.
6. Address preservation, reasonable search, deduplication, threading, families,
   date and time zones, OCR, load files, numbering, confidentiality designations,
   redactions, privilege logs, clawback, and rolling production only as the actual
   procedure permits.
7. Reconcile requests against material already supplied. Do not demand duplicates
   without explaining the missing version, attachment, metadata, or completeness
   issue.
8. Draft response and objection deadlines from verified rules or orders. Show the
   source and calculation; do not infer extensions or holiday treatment.
9. Prepare a focused deficiency and meet-and-confer agenda before seeking relief.
   Preserve agreements, disputed points, proportional compromises, and next steps.

## Output

Provide the issue-to-request matrix, numbered draft requests, definitions and
instructions, format and metadata schedule, proportionality record, anticipated-
objection table, narrower fallback set, deadline note, and meet-and-confer agenda.

## Guardrails

Do not request privileged, protected, irrelevant, oppressive, illegally obtained,
or unnecessarily sensitive material. Do not represent that a request is permitted
or compulsory without the governing procedure. Preserve adverse material and do
not use disclosure demands to harass, expose protected identities, or bypass
privacy, secrecy, employment, blocking-statute, or cross-border restrictions.