{"id":17263,"plugin_id":"plugins_6a75dc82c0fc81919985d8f2dc208355","kind":"skill","collection_source":null,"comparison_source":null,"observed_at":"2026-09-30T23:14:04.784Z","digest":"1b31d0f77491ba7cde49e79c6df889a6ac7686553dea9258a4fc0662e114808a","against":null,"payload":{"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.","included_files":[{"relative_path":"agents/openai.yaml","size_in_bytes":287}],"name":"disclosure-request-drafter","skill_md_contents":"---\nname: disclosure-request-drafter\ndescription: >-\n  Drafts targeted requests for disclosure, discovery, inspection, production,\n  interrogatories, admissions, or further information in litigation or similar\n  proceedings. Use when requests must be tied to pleaded issues, custodians,\n  sources, time periods, proportionality, format, metadata, privilege, objections,\n  deadlines, or a meet-and-confer process.\n---\n\n# Disclosure Request Drafter\n\nDraft enforceable, proportionate requests that seek information needed to resolve\nidentified issues rather than conducting an unsupported fishing exercise.\n\n## Intake\n\nObtain the jurisdiction, forum and current rules or order; pleadings and live\nissues; burdens and defences; existing disclosures; disputed requests and\nresponses; known custodians, systems and date ranges; search or technology\nprotocols; confidentiality arrangements; privilege position; deadlines; and the\npurpose for which each requested category is needed.\n\nDo not assume that common-law discovery, civil-law disclosure, arbitration\ndocument production, regulator demands, and criminal disclosure use the same\ntest, terminology, scope, or remedy.\n\n## Method\n\n1. Build an issue-and-element map before drafting. Link every request to a pleaded\n   allegation, defence, remedy, credibility issue, or defined procedural purpose.\n2. Select the correct procedural device and recipient. Separate document requests,\n   inspection, interrogatories, admissions, particulars, third-party process, and\n   informal requests.\n3. Define documents and electronically stored information precisely, including\n   date range, custodian, system, subject, document family, version, attachment,\n   communication channel, structured-data fields, native format, and metadata only\n   where justified.\n4. Use objectively testable language. Avoid vague terms such as \"relating to\" or\n   \"all documents\" unless narrowed by a clear subject and proportional scope.\n5. For each request, record relevance, expected source, burden, likely objection,\n   narrower fallback, and why another source is inadequate or less efficient.\n6. Address preservation, reasonable search, deduplication, threading, families,\n   date and time zones, OCR, load files, numbering, confidentiality designations,\n   redactions, privilege logs, clawback, and rolling production only as the actual\n   procedure permits.\n7. Reconcile requests against material already supplied. Do not demand duplicates\n   without explaining the missing version, attachment, metadata, or completeness\n   issue.\n8. Draft response and objection deadlines from verified rules or orders. Show the\n   source and calculation; do not infer extensions or holiday treatment.\n9. Prepare a focused deficiency and meet-and-confer agenda before seeking relief.\n   Preserve agreements, disputed points, proportional compromises, and next steps.\n\n## Output\n\nProvide the issue-to-request matrix, numbered draft requests, definitions and\ninstructions, format and metadata schedule, proportionality record, anticipated-\nobjection table, narrower fallback set, deadline note, and meet-and-confer agenda.\n\n## Guardrails\n\nDo not request privileged, protected, irrelevant, oppressive, illegally obtained,\nor unnecessarily sensitive material. Do not represent that a request is permitted\nor compulsory without the governing procedure. Preserve adverse material and do\nnot use disclosure demands to harass, expose protected identities, or bypass\nprivacy, secrecy, employment, blocking-statute, or cross-border restrictions.\n"},"changes":[],"summary":"First saved snapshot. No earlier version is available for comparison.","summary_kind":"deterministic","summary_metadata":{}}