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Claude Prompt: Discovery Deficiency Analysis and Meet-and-Confer Letter (PI)

Compares the requests you served with the responses and objections you received, classifies every deficiency with both texts quoted, and drafts the meet-and-confer letter with your response date.

The Prompt

Variables (9)

VariableDescriptionExample
{{court_and_jurisdiction}}Court and JurisdictionCircuit Court of Cook County, Illinois, Law Division (state court)
{{governing_discovery_rules}}Governing Discovery and Meet-and-Confer RulesIllinois Supreme Court Rules 201(k), 213 and 214 (text pasted below); standing order of the assigned judge requiring a telephone conference before any discovery motion.
{{responding_party}}Responding PartyDefendant Sunline Logistics LLC
{{opposing_counsel_name}}Opposing Counsel NameRebecca Thornton, Hale & Thornton LLP
{{service_and_response_dates}}Service and Response DatesInterrogatories and requests for production served 11/03/2025; responses served 12/12/2025
{{response_deadline_date}}Requested Date for Supplemental Responses2026-01-16
{{discovery_requests_served}}Discovery Requests ServedREQUEST FOR PRODUCTION NO. 7: All driver logs, dispatch records and telematics data for the vehicle operated by Daniel Reyes on March 14, 2025.
{{responses_and_objections_received}}Responses and Objections ReceivedRESPONSE TO REQUEST NO. 7: Objection. Overbroad, unduly burdensome, vague and not proportional. Subject to and without waiving these objections, Defendant will produce responsive documents, if any.
{{production_description}}Description of the Production ReceivedSUN000001-000240 produced 12/12/2025: personnel file, insurance policy, 3 pages of driver logs for 03/14/2025. No telematics data. No privilege log served.

Expected Output

An analysis block, then two parts. Part 1, attorney-only notes: (A) a deficiency table quoting each request and response, with label, cure and priority; (B) conflicts between sources and recomputed counts (pages, Bates ranges, days promised against days produced); (C) points that depend on rules you did not paste, such as verification or a privilege log; (D) requests answered adequately; (E) unsupported statements declined; (F) declined requests; (G) missing information. Part 2, the meet-and-confer letter with your response date, free of markers, ratings and internal notes. A verification list closes the output.

Usage Notes

Use as soon as responses arrive. Paste the requests and the responses in full, describe the production (Bates ranges, whether a log and a verification were served), and paste your court's rules on objections, verification, privilege logs and the pre-motion conference. Without that rule text the prompt will not demand a verification or a privilege log in the letter: those points are parked in Part 1 for you to research. The letter carries one date only, the response date you supply, and each cure is the request itself, restated. Failure modes to watch for: a cure that asks for more than the request did, and a case cited in the other side's objection being treated as real; every such citation is on the verification list to be pulled and read. The federal rules listed are reference points and do not govern a state-court case. Read the document part line by line before it leaves the office: in testing, a small model sometimes left an internal remark, a comparison with the file or an unresolved point inside the document despite the instructions. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.

Legal Sources Referenced

Originally featured in: AI for Personal Injury Lawyers: Prompts for Demand Letters, Medical Summaries & Depositions

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* These prompts are drafting and analysis aids for licensed attorneys. They are not legal advice and do not replace professional judgment. AI output can contain errors, including invented citations and incorrect deadlines: verify every fact, figure, authority and deadline against primary sources before relying on it. Rules vary by jurisdiction, and you remain responsible for the final work product.