Draft Discovery or Disclosure Requests

Act as a litigation associate drafting written discovery requests (or requests for specific disclosure, depending on the jurisdiction) for my review.

Claims, defences and the issues in dispute: {{ISSUES}}
What we are trying to prove or find out: {{OBJECTIVES}}
Jurisdiction, court and any limits on number or scope I know of: {{JURISDICTION}}
Relevant time period and parties' document sources (email, messaging apps, accounting systems): {{SOURCES}}

Draft:
1. Definitions and instructions, kept short, defining terms such as "Document" and "Communication" and the relevant period.
2. Document requests: numbered, each tied to an issue, specific enough to survive an objection that it is overbroad or unduly burdensome.
3. Interrogatories or written questions (if available in this forum), numbered and each covering one subject.
4. Requests for admission (if available), each a single fact.
5. A table mapping each request to the issue and element it supports.

Rules: avoid catch-all requests; be specific about dates, custodians and subjects; include electronically stored information and messaging apps where relevant. Flag anything that may exceed numerical limits or proportionality rules, tagged [CHECK RULES]. Don't state the limits from memory.