---

name: prompt-pack-discovery-request
description: Use when drafting discovery requests — interrogatories, requests for production of documents, and requests for admission — for civil litigation proceedings. Covers proportionality, relevance standards, and compliance with procedural rules across jurisdictions. Relevant for disputes practitioners in UAE courts, DIFC/ADGM courts, Lebanon, Egypt, KSA, UK, EU, and US proceedings. Trigger when a client needs formal discovery instruments to compel disclosure of evidence from the opposing party.
license: MIT
metadata:
id: prompt-pack.discovery-request
category: prompt-pack
practice_area: disputes-litigation
jurisdictions: [UAE, DIFC, ADGM, LB, EG, KSA, UK, US, EU]
priority: P2
intent: [drafting, discovery-request, interrogatories, document-production, requests-for-admission]
related:
- prompt-pack-document-production-request
- prompt-pack-injunction-application
- prompt-pack-enforcement-of-judgment
- prompt-pack-expert-witness-report-outline
source: Louis — HAQQ Legal AI (github.com/sboghossian/mini-claude-for-legal)
version: "1.0"

Discovery Request

When to use this

Use this skill when a litigant needs to compel the opposing party to provide evidence in pre-trial or pre-hearing proceedings. Discovery instruments vary significantly between common-law adversarial systems (where broad pre-trial discovery is the norm) and civil-law inquisitorial systems (where the judge controls evidence gathering and party-driven discovery is limited).

Typical triggers:

• Counsel needs interrogatories to pin down the opposing party's version of facts
• Document production is needed to build or defend the case
• Requests for admission are needed to narrow issues before trial
• Client is in US, UK, DIFC, or ADGM proceedings where formal discovery is available

Important: In civil-law jurisdictions (Lebanon, Egypt, UAE onshore, KSA, France), pre-trial party-driven discovery of the US/UK type does not exist. The equivalent is a court-ordered disclosure request (see [[prompt-pack-document-production-request]] for the arbitration equivalent). Adapt this skill accordingly.

Required inputs

Input	Why it matters	Default if omitted
Client / requesting party	Identifies who is propounding the requests	Ask before proceeding
Case name and number	Proper caption required	Ask
Jurisdiction and court/forum	Determines procedural rules that govern	Ask; critical
Key factual issues to be proven	Drives which categories of requests to draft	Ask in detail
Opposing party name	Identifies respondent	Ask
Stage of proceedings	Discovery is time-sensitive; rules govern when requests may be served	Ask

Optional inputs

• Existing pleadings or statement of claim/defense (to calibrate specific requests)
• Prior discovery responses (to assess gaps)
• Privilege log expectations
• Discovery limits (e.g., US federal FRCP Rule 33 limits interrogatories to 25 without leave of court)
• Electronic discovery (e-discovery) scope and custodians

Document structure

Interrogatories

1. Caption and instructions — Case caption; definitions section (define "you," "document," "communication," "relating to," etc.); instructions on answering under oath and objection procedure.

2. Background interrogatories — Identify all persons with knowledge; identify all documents relevant to the disputed facts.

3. Merits interrogatories — Targeted to each disputed element:

   • Identify all persons with knowledge of [specific transaction/event]
   • Describe all communications with [counterparty] regarding [subject]
   • State the basis for the claim that [specific assertion in pleadings]

4. Damage/quantum interrogatories — Identify all losses claimed; describe calculation methodology; identify all mitigation steps taken.

5. Verification block — Signature under oath by a party officer or authorized representative.

Requests for Production (RFP)

1. Caption and instructions — Same as interrogatories; include definitions for "document" (broad: paper, electronic, metadata, voicemails, etc.) and "electronically stored information" (ESI).

2. Document categories — Numbered requests, each targeting a specific category:

   • All contracts between the parties relating to [subject]
   • All communications (email, messaging, written) from [date range] concerning [topic]
   • All financial records evidencing [payment, loss, valuation]
   • All board minutes, resolutions, and internal approvals relating to [decision]
   • All expert materials, analyses, or valuations prepared in connection with [matter]

3. ESI protocol reference — If agreed, reference the parties' ESI protocol or propose one.

Requests for Admission (RFA)

1. Caption and instructions — Failure to respond within the deadline (28 days in US federal court; similar in DIFC/ADGM) results in deemed admission.

2. Fact admissions — "Admit that on [date], [party] executed the contract attached as Exhibit A."

3. Authenticity admissions — "Admit that the document attached as Exhibit B is a true and accurate copy of [document description]."

4. Legal conclusion admissions (use sparingly) — "Admit that [party] breached the obligation set forth in Clause 5.2 of the Agreement."

Jurisdictional notes

Jurisdiction	Discovery regime	Key rules
DIFC Courts	Common-law adversarial; broad discovery	DIFC Courts Rules Part 28; disclosure obligations similar to English CPR Part 31
ADGM Courts	Common-law; modeled on English procedure	ADGM Court Procedure Rules; standard disclosure plus specific disclosure on application
UAE Onshore	Civil-law inquisitorial; no party-driven discovery	Judge requests documents; parties submit evidence with pleadings; Federal Law of Evidence governs
KSA	Sharia-based civil procedure; judge-directed	Evidence Code; expert witnesses appointed by court, not parties
Lebanon	French-model civil procedure (NCPC equivalent)	Juge de la mise en état can order production; party-driven requests go through judge
Egypt	Civil Procedure Law; judge-directed	Parties can request court to order production; broad discovery unknown
UK	CPR Part 31 standard disclosure + specific disclosure	Duty to preserve from time of litigation hold; Peruvian Guano test for relevance (broad)
US Federal	FRCP Rules 26–37; broad pre-trial discovery	Rule 26 initial disclosures; 25-interrogatory limit; proportionality standard post-2015

Drafting standards

• Each request must be framed to be: (a) relevant to a claim or defense, (b) proportionate to the needs of the case, (c) specific enough to identify the information sought.
• Avoid omnibus requests ("all documents relating to the dispute") that will draw objections — break them into targeted categories.
• Use defined terms consistently throughout all three instruments.
• In common-law systems, include a litigation hold reference in the cover letter accompanying the requests.
• In civil-law systems, reframe as an application to the court or tribunal requesting a document production order, citing the specific facts and legal provision that supports compelled disclosure.

Common mistakes

• Over-broad requests: Courts routinely sustain "overbreadth" objections; draft tightly and you will get more.
• Failure to define ESI scope: Without an agreed e-discovery protocol, massive disputes arise over format, custodians, and search terms.
• Missing the deadline: Discovery requests in most systems must be served within fixed periods after filing; check the applicable rules.
• Applying US-style discovery to civil-law proceedings: Civil-law courts do not recognize interrogatories as a mechanism; use the court's procedural tools instead.
• No verification: Interrogatory answers must be verified under oath by an authorized party representative; unsigned answers are defective.

Related skills

• [[prompt-pack-document-production-request]]
• [[prompt-pack-injunction-application]]
• [[prompt-pack-enforcement-of-judgment]]
• [[prompt-pack-expert-witness-report-outline]]