Draft Legal Discovery Requests

I need ten written requests for production of legal documents ready to serve on the opposing party no later than 20 March. The matter is in arbitration, so the drafting must be tight, rule-compliant, and strategically focused on what we truly need before our 6 May status conference.

You will receive the pleadings, timeline, and any correspondence already exchanged. From there, craft the requests, weave in clear definitions and instructions, and build in language that preserves privilege and addresses the handful of documents that demand special confidentiality handling. Objections to these requests will land on 3 April, and any uncontested materials are due 17 April, so the wording has to be defensible from the start.

Deliverables
• Word document containing ten numbered document requests, ready for service
• Brief memo explaining the reasoning behind each request and detailing the privilege / claw-back provisions included

Acceptance criteria
• Conforms to applicable arbitration or Rule 34 standards
• Addresses privilege and confidentiality concerns explicitly
• Delivered to me by 17 March for quick internal review

Familiarity with U.S. discovery practice, subpoenas, and protective orders is essential, as the respondent may later subpoena the DOT and we may subpoena the Geng & Assoc. firm. I’ll stay available for rapid feedback so we can hit every deadline comfortably.