AI Prompt: Requests for Production to the Defendant in Personal Injury Cases
Draft personal injury requests for production to the defendant from your own case facts, with definitions, protective-order flags and a count check against the rules you paste.
The Prompt
Variables (7)
| Variable | Description | Example |
|---|---|---|
| {{court_and_jurisdiction}} | Court and Jurisdiction | Superior Court of Maricopa County, Arizona (state court) |
| {{governing_discovery_rules}} | Governing Discovery Rules | Paste the full text of the rule on requests for production, any numerical limit, timing and ESI form provisions, and the scheduling order. |
| {{responding_defendant}} | Responding Defendant | Ridgeline Freight Inc. |
| {{case_type_and_defendant_type}} | Case Type and Defendant Type | Commercial vehicle collision; defendant is a trucking company and its driver |
| {{claims_and_issues}} | Claims and Issues | Negligence against driver; vicarious liability and negligent hiring and training against the company. Defense disputes speed and driver fatigue. |
| {{orders_and_agreements}} | Protective Order and ESI Agreements | No protective order entered. ESI agreement: none. |
| {{case_facts_and_evidence}} | Case Facts and Evidence | Crash report 24-118733, p. 2: "Unit 1 failed to stop." Preservation letter sent 03/04/2026 to Ridgeline Freight. Complaint paras. 8-14. |
Expected Output
Part 1 attorney-only notes (evidence register, conflicts between sources, request table with the claim or issue each request serves, count and cut order, protective order and in camera flags, declined requests, missing information) and Part 2 the requests ready for attorney review (definitions, instructions, numbered requests), then a Verification list.
Usage Notes
Use after the answer or initial disclosures, when you know the claims and the court's discovery rules. Paste the rule text itself, not a summary. Failure mode to watch: a request built on a category the file does not support (for example prior incidents or punitive-damages financials) or a time frame the model chose; check that every request maps to a claim or fact you supplied. Read the document part line by line before it leaves the office. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Double-check before use
- Check that no definition or request asserts a fact found only in your notes.
These are the places where this prompt was seen to slip when tested on sample cases with a small AI model.
Legal Sources Referenced
- Fed. R. Civ. P. 34 (requests for production of documents, electronically stored information and tangible things)
- Fed. R. Civ. P. 26(c) (protective orders)
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.