Draft Civil Discovery Requests

I’m preparing to serve discovery in an active civil matter and need a seasoned hand to draft two sets of written discovery: (1) Requests for Production and (2) Requests for Admission. My objective is to gather precise, admissible information while avoiding boiler-plate language that will trigger needless objections.

Here’s what I will provide once we get started: a concise case summary, the current pleadings, and the factual points I need to prove or disprove. From that, I am looking for thoughtfully-worded requests—each tied to an element of the claim or defense, properly numbered, and citing the governing rules for our jurisdiction. Clarity, proportionality, and strategic sequencing are more important to me than sheer quantity of requests.

Deliverables (Word or Google Doc are fine)
• A polished set of Requests for Production
• A separate, numbered set of Requests for Admission
• A short cover note explaining any key drafting choices or follow-up suggestions

I will review immediately and turn the documents around quickly, so availability for one prompt revision is appreciated. If you have solid litigation or paralegal experience and a knack for crafting discovery that actually gets answered, I’d like to work with you.