| name | discovery-verification-audit |
| title | Discovery Verification and Proof of Service Audit |
| description | Produces an attorney-grade audit memorandum assessing whether written discovery responses are legally binding and timely. Use this skill when the user mentions verification audit, discovery verification, proof of service review, signature authority, perjury clause compliance, deadline computation, mailbox rule extensions, service defects, waiver risk, or motion-to-compel deadline analysis. Also trigger when the user references FRCP 33(b)(3) verification, CCP 2015.5, 28 U.S.C. 1746, attorney vs. party verification, or asks for help checking whether discovery responses are properly executed. Even if the user just says "check these responses for defects" or "is this verification valid," use this skill. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/discovery-verification-audit |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | litigation |
| language | en |
| tags | ["analysis","drafting","memo"] |
Discovery Verification and Proof of Service Audit
Why This Skill Exists
Unverified or improperly verified discovery responses are a legal nullity in many jurisdictions — they can be treated as no response at all, waiving objections and restarting motion-to-compel clocks. Yet verification defects are among the most overlooked issues in practice because they sit on back pages that attorneys rarely scrutinize. A single wrong signature (attorney where party is required), a missing perjury clause, or a botched deadline computation can be either a devastating vulnerability for your client or a powerful weapon against an opponent.
This skill produces a structured audit memorandum covering verification sufficiency, signature authority, proof of service, deadline computation, and defect risk assessment across federal and state forums.
Checkpoint A: Pre-Draft Intake (Mandatory)
Ask every time unless the user says "use defaults" or "just draft." Gather:
- Discovery set and responses — propounding requests and full response package as served, including all signature/verification pages and attachments
- Proof(s) of service — for both the requests and the responses; ECF notices, certified mail receipts, courier confirmations, or email headers if e-service is authorized
- Forum identification — jurisdiction (state + county or federal district), governing procedural rules (FRCP, CCP, etc.), and any applicable local rules or standing orders
- Deadline modifiers — stipulations, court orders, or extensions modifying response deadlines
- Party identity — responding party type (individual, corporation, LLC, government entity), signer's name and title, and basis of authority
- Master service list — all parties and counsel of record to verify service completeness
- Audit posture — outgoing (pre-service QA) or incoming (opponent defect analysis)
If the user doesn't respond, apply and clearly label these defaults: incoming audit (opponent defect analysis); federal court; FRCP governing rules.
If the verification page(s), proof of service, or any deadline-modifying order is missing, request those documents before reaching conclusions.
Step 1: Confirm Scope and Posture
Document the audit scope:
- Discovery instruments audited (interrogatories / RFPs / RFAs / supplemental / amended responses)
- Audit posture: outgoing (pre-service QA) or incoming (opponent defect analysis)
- Governing rule set confirmed; any inferences flagged for attorney confirmation
