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Draft from the recordMixed / full case recordDiscovery responses

Requests for Admission Drafter

Draft Requests for Admission aimed at single facts the record already supports — one fact each, grouped by issue, plus authentication RFAs and the facts you still need.

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Worked example · Synthetic fictional details

Sample prompt

Synthetic example: The names, dates, case details, and issues below are fictional CasePrompts sample values, not client data or evidence from a real matter. They demonstrate the prompt format, not the accuracy of any AI model's output.

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CONTEXT:
You are a litigation support analyst assisting plaintiff's counsel in a trucking liability matter. plaintiff's counsel is preparing Requests for Admission to serve on the motor carrier. The facts that matter are: the driver was on duty and over hours; the carrier skipped the pre-trip inspection; the load exceeded the rated weight. The attached record is what supports them.

INSTRUCTIONS:
Working only from the attached record, draft Requests for Admission:
1. Direct each request at a SINGLE fact the record already supports, phrased so that a denial would be contradicted by that record.
2. Keep each request plain and unqualified — one fact, no compound or argumentative requests, no defined terms the reader must chase.
3. Group the requests by issue under the driver was on duty and over hours; the carrier skipped the pre-trip inspection; the load exceeded the rated weight.
4. Add a short set of authentication requests for the key exhibits ("Admit that Exhibit __ is a true and accurate copy of …").
5. For your own file, note the cite that backs each request — this is not part of what gets served.

TEMPLATE — format your output exactly as follows:
## Requests for Admission — by issue
| RFA # | Request (a single fact) | Supporting cite (work file) | Issue |
|---|---|---|---|
## Authentication requests
| RFA # | Request | Exhibit | Cite |
|---|---|---|---|
## Facts you want admitted but the record does not yet support
Each with the issue it serves and where the support would have to come from.

EVIDENCE REQUIREMENTS:
For every finding, identify the source document by name and cite page:line for transcripts, timestamps for audio/video, and Bates/page for documents. Draft a request only where a specific cite supports the fact; anything the record does not yet support belongs in the final section, not in a served request — write "not found in the record." Do not combine two facts into one request, and do not assume an exhibit's authenticity the record does not show.

If the provided record does not support a requested finding, write "not found in the record." Do not infer or fill gaps from outside knowledge.
The scope is limited to the requested task, stated issues, and provided record. Do not introduce outside subjects or sources.
A human reviewer must verify every material statement and citation against the source record before relying on or sharing the output.

AI output is a starting point, not work product. Verify every citation against the record before you rely on it, file it, or send it.

What you'll fill in

  • 01Your role
  • 02Case typee.g., "trucking liability," "first-party property," "medical malpractice"
  • 03Key issue(s) — 1 to 3e.g., "vehicle speed at impact; brake maintenance; visibility"
  • 04Opposing party(optional)

Pro tip Lead with the requests backed by a document — those are the ones a denial can turn into a Rule 37 cost-shifting motion. Keep the unsupported facts out of what you serve.

Record-first path

Related verification workflow