| name | discovery-deficiency-tracker |
| title | Discovery Deficiency and Meet-and-Confer Tracker |
| description | Builds and maintains a litigation-grade discovery deficiency and meet-and-confer tracker for compulsion motion practice. Use this skill when the user mentions deficient discovery responses, motion to compel preparation, meet-and-confer tracking, FRCP 37 sanctions, discovery dispute charts, joint discovery letters, informal discovery conferences, deficiency logging, or California Separate Statements. Also trigger when the user references boilerplate objections, privilege log deficiencies, incomplete productions, evasive answers, discovery conferral documentation, or asks for help organizing disputes for court. Even if the user just says "track these discovery problems" or "help me build a compel motion," use this skill. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/discovery-deficiency-tracker |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | litigation |
| language | en |
| tags | ["analysis","checklist","drafting","letter","summary"] |
Discovery Deficiency and Meet-and-Confer Tracker
Why This Skill Exists
Discovery disputes are won or lost on organization and documentation, not on the merits of any single objection. Without a structured, request-by-request tracker, deficiencies blur together, conferral history gets lost in email threads, deadlines slip, and the motion to compel becomes a credibility fight about who said what. Courts increasingly require detailed dispute charts and documented good-faith conferral before entertaining any compulsion motion.
This skill produces a tracker that serves as the factual backbone for FRCP 37 motions to compel, sanctions requests, informal discovery conferences, joint letters, and California Separate Statements — with every assertion grounded in verbatim quotations from primary sources.
Checkpoint A: Pre-Draft Intake (Mandatory)
Ask every time unless the user says "use defaults" or "just draft." Gather:
- Full discovery requests — complete text of each disputed interrogatory, RFP, or RFA, including definitions, instructions, and identifiers
- Complete written responses — exact response text as served, including all general and specific objections, verifications, and any "subject to and without waiving" language
- Production records — Bates ranges for documents produced, privilege logs served, and supplementation dates/descriptions
- All conferral communications — emails, letters, call notes in chronological order; any court orders relating to discovery
- Governing orders — protective order, ESI order, clawback agreement
- Scheduling deadlines — discovery cut-off, motion cut-off, and any forum-specific compel deadlines
- Forum identity — court, assigned judge, local rules URL, and standing/individual rules
If the user doesn't respond, apply and clearly label these defaults: federal court; FRCP 26–37 governing rules; all disputed requests included; court-facing chart format.
If exact request/response text or applicable deadlines are missing, pause and prompt the user before generating a court-ready tracker. Label provisional entries [ATTORNEY VERIFICATION NEEDED].
Step 1: Build the Tracker Schema
Create one entry per disputed request number. Never combine multiple requests in a single row.
