Skill

Discovery Plan (Template)

A litigation discovery plan: what to request, why, and what it proves.

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Steps

  1. Write the 1-sentence case theory and 1-sentence defense theory.
  2. List the elements you must prove.
  3. Map each element to specific discovery targets.
  4. Identify third parties and time-sensitive subpoenas.

Output Template

Discovery Plan

Case theory (1 sentence):
Defense theory (1 sentence):

What we must prove (elements):
- …

Discovery targets (what we want + why):
- Target: [DOC/ESI/DEPO] | Owner/Custodian: [ ] | Why it matters: [ ] | Proves: [element]

Third parties
- [ ] subpoena: [what] | deadline risk: [ ]

Risks
- Spoliation/video overwrite
- Privacy/HIPAA

Quality Checks

  • Every request ties to an element or defense.
  • Third-party requests are prioritized by overwrite/deadline risk.