Discovery requests are drafted twice by most lawyers: once badly, from a form bank, and once well, after the first round comes back with nothing but objections. The difference is not cleverness. It is starting from what you actually need to prove or disprove, then writing each request so there is no comfortable way to dodge it. A request that can be answered with 'see documents produced' or 'objection, vague' was written for the file, not for the case.

Interrogatories and document requests do two different jobs. Interrogatories lock a party into a sworn, specific position — a fact, a date, a list of witnesses, a computation. Document requests get you the paper and electronic record that either supports or contradicts that position. Used together, and sequenced correctly, they build the factual record a motion for summary judgment or a trial will later stand or fall on. Juricratic does not draft discovery for you, but treating each request as an input to a specific fact you plan to prove is the same discipline that makes a litigation simulation useful: every input has to trace back to something you can defend.

Before drafting a single request, list the elements you must prove (or the defenses you must support) and, next to each, the specific fact still missing or unconfirmed. Every request should map to one of those gaps. If a request does not trace to an element, a defense, a damages component, or a credibility point, cut it — volume without purpose is what makes discovery expensive and slows down the requests that actually matter.

This mapping also protects you later. When opposing counsel objects that a request is overbroad or not proportional to the needs of the case, you want to be able to say in one sentence why the request matters: it goes to element X, or it tests the credibility of witness Y. Requests you cannot justify that way are usually the ones a court will narrow or strike.

The most common interrogatory-drafting mistake is asking a question broad enough that a generic answer technically satisfies it. 'Describe the accident' invites a paragraph of narrative hedging. 'State the exact time you first applied the brakes, to the nearest second you can estimate, and identify the basis for that estimate' does not.

Contention interrogatories — asking a party to state every fact supporting a claim, defense, or denial — are especially useful late in discovery, after documents are in hand, because they force the other side to commit to a position you can then test against the record.

Courts increasingly police discovery for proportionality — whether the burden of producing something is justified by its likely importance to the case. A request for 'all documents relating to the contract' invites a legitimate overbreadth objection. A request for 'all emails between the two named negotiators discussing the pricing term, from six months before signing through the signing date' is far harder to resist.

Bound every document request by subject matter, custodian, and time period wherever you can. If you genuinely need a broader universe searched, say so and explain why — proportionality objections are much weaker when the requesting party has already shown restraint.

A short definitions section, placed before the numbered requests, does more to eliminate evasive answers than any amount of extra requests. Define ambiguous terms once — 'the Agreement,' 'the Incident,' 'Communication,' 'Identify' — and every request that uses them becomes tighter without becoming longer.

Standard instructions should state the time period covered if not otherwise specified, the format expected for a privilege log, and that the requests are continuing under the applicable discovery rule, so a party cannot claim it had no obligation to supplement.

Read each request once more as if you were the party receiving it, looking for the objection you would raise: vague, overbroad, not proportional, seeks privileged material, calls for a legal conclusion. Where you can narrow a request preemptively without losing what you need, do it — it removes an easy objection and speeds up the eventual meet-and-confer.

If you expect a fight over a specific request, decide in advance what you would accept as a compromise (a narrower date range, a sample production, a privilege log by category) so the meet-and-confer moves toward resolution instead of restating positions. A motion to compel should be the last step after a documented, good-faith attempt to resolve the dispute — not the first response to an objection.