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Propound Discovery

Brainstorm and propound discovery questions including interrogatories, document requests, and requests for admissions.

Updated over 6 months ago

Summary

In this guide we will take you through the steps of working with Eve to propound discovery. First you will upload all of your key documents and set your instructions, then you will ask Eve to propound discovery, including Interrogatories, Document Requests, and Requests for Admissions. This step-by-step guide will take you through this process and includes sample messages to use with Eve.

Hack tip! Use the Propounding Discovery skills

Go into the Skills view of Eve. You will be able to leverage the general "Propounding Discovery" skill or the specialized "Draft Interrogatories", "Draft RFAs", or "Draft RFPs" skills.

Step-by-Step Instructions

Step 1: Upload relevant documents

Upload the essential documents that will inform your discovery requests. These may include previous correspondence, letters, briefs, client provided background information or supporting documents, and key pieces of evidence. The more comprehensive your case file, the more information Eve will have at her disposal to brainstorm interrogatories for you. For more information on uploading documents to Eve click here.

Step 2: Set your Instructions

You can also set Eve “Instructions”. Instructions are for high-level information about you as a user, your firm, your preferences and any pertinent background information you like to provide to Eve when working with Eve on a particular task. Read more about instructions here.

Example Instructions for working on propounding discovery:

🗒️ You are an advanced legal case assistant tasked with assisting in propounding discovery. You will help with drafting precise discovery documents such as interrogatories, requests for production, and requests for admissions. Your responses should be clear, precise, and tailored to facilitate the efficient and effective gathering of information necessary for case advancement.

Step 3: Define the scope and objectives of your discovery

First, set the scope an objectives you have for discovery. For example, which requests do the particular facts and elements of your case require? What type of information do you need to uncover? How will the requests fit into and align with your overall case strategy?

Eve can help with this. Just ask Eve to help you brainstorm case strategy, potential holes in your case, and to predict opposing counsel's response and strategy to inform your discovery plan.

You can then use this type of information or any specific case strategy determined in prior work to inform Eve’s responses by referencing it in the messages you craft or add it to the instructions panel. For instance in the example for Crafting Interrogatories below we include the phrase “which could prove a fact essential to establishing an element of our claim.”

💡 Pro Tip: Use specific case language in messages and outlining the claims you are currently pursuing in Eve's instructions to provide Eve with your overall goals and inform Eve of exactly the type of requests you’re looking to craft.

Step 4: Generate your discovery requests

Now you can begin to generate your discovery requests.

It’s easy, just ask. Be as specific as possible and provide Eve with any context that may be important, as seen in the below examples. For each request, be ready to iterate, and ask Eve to expand the list, contract it, or re-work it with a different focus. If the answer you get from Eve isn’t what you’d like, correct and ask again - you can find best practices for iterating on work with Eve here.

Let’s work through three kinds of requests - interrogatories, request for document production, and request for admission.

Crafting Interrogatories with Eve

Ask Eve to draft you a number of interrogatories. In your message to Eve, include any pertinent details or focus that Eve should have when writing.

💬 Example Message: Create 15 specialized interrogatories. These should be aimed at discovering the names of individuals who may serve as witnesses, or locating documents (including those in electronic format), which could prove a fact essential to establishing an element of our claim, or a fact that directly constitutes such an element.

💡 Pro Tip: Once your interrogatories have been generated save them to your project for easy access and collaboration with Eve when refining or using the interrogatories. See how to easily do so in the below section “Step 5: Reviewing and Finalizing Discovery Requests”.

Preparing Document Requests (Request for Production) with Eve

Ask Eve to draft you a number of requests for production of documents. In your message to Eve, include any pertinent details or focus that Eve should have when writing.

💬 Example Message: Create 25 requests for production of documents. A request for production of documents is appropriate when relating to a matter that supports one or more of the elements of our causes of action, or counteracts an affirmative defense seeking to identify a witness, or documents (including those in electronic format), which could prove a fact essential to establishing an element of our claim, or a fact that directly constitutes such an element.

Formulating Requests for Admissions with Eve

Ask Eve to draft you a number of requests for admissions. In your message to Eve, include any pertinent details or focus that Eve should have when writing.

💬 Example Message: Create 15 requests for admissions. Such requests are appropriate when they support one or more of the elements of our causes of action, or counteract an affirmative defense seeking to identify a witness, or documents (including those in electronic format), which could prove a fact essential to establishing an element of our claim, or a fact that directly constitutes such an element.

Bonus: Building a witness list with Eve

Ask Eve to draft you a witness list. In your message to Eve, include any pertinent details, what information should be presented for each witness, relevance to the case, etc.

💬 Example Message: Create a witness list identifying all witnesses and what they would have personal knowledge about in the context of proving elements of our claim or disproving opposing counsel’s affirmative defenses

💡 Pro Tip: If you find that you use these same questions repeatedly on cases, you can use the “Teach Eve” button to save your messages and easily re-use them later. Read more here.

Step 5: Reviewing and Finalizing Discovery Requests

Now that you’ve drafted your discovery request(s) it’s time to review and finalize them. We’ll continue the example with drafting a set of interrogatories, but the process will be the same for other types of discovery requests.

To create an interrogatories document we're going to open a blank document that we can edit as we go.

Click the “Upload Documents” button in your project. Select the Text tab and enter a relevant name for your letter and paste the interrogatories into the text field:

You can learn more about opening a working document with Eve here.

Alternatively, you may ask Eve either in your original message or in a follow up message to put your interrogatories into a “code block,” which will allow you to simply use the “save to project” button present in the code box to save your work to the project as seen below.

At this point you’re ready to keep working with Eve to finalize your discovery requests. With the document saved to your project you can edit in real time with Eve while asking questions, or ask Eve to re-draft or better explain portions of your requests.

You can find more information on jointly drafting and iterating on documents with Eve here.

By following these steps you should be able to draft your propounding discovery documents in a matter of minutes.


If you have any questions about propounding discovery with Eve, don't hesitate to reach out to our support team at support@eve.legal.

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