How to Respond to Discovery Requests in Eve

Overview

Eve drafts responses to discovery requests, such as interrogatories, requests for production, requests for admissions, and bills of particulars, formatted the way your firm formats them. The work happens inside the matter, using the propounded discovery document and the case documents you select.

Formatting and tone come from a discovery response agent, which is trained once on your own completed response documents and then reused on every matter after that. Discovery response agents are their own agent type, separate from drafting agents.

Before You Start

• Access to the matter where the responses will be drafted.

• The discovery document propounded by the opposing party, either already in the matter or ready to upload.

• Key case documents in the matter: case overview or consult notes, relevant medical records, the police or incident report, prior correspondence with opposing counsel.

• Two to ten complete response documents in .docx format, if no discovery response agent exists yet. These are the examples Eve learns the format from, so use finished work product rather than a template with the fields empty.

Drafting the Responses

1. Open the matter.

2. Open Agents and select the Discovery Response agent.

3. Select the propounded discovery document. Search the matter's files by name, or upload the document if it is not in the matter yet. The selected document becomes the set of requests Eve responds to, so confirm it is the right one before continuing.

4. Select the discovery response agent to format with, or click Create new discovery response agent to build one.

5. If creating one, upload your complete .docx response documents, give the agent a name, and choose whether to share it with the firm. Eve builds the agent from the structure, tone, and formatting of the examples and selects it automatically. Click Next.

6. Select the case documents Eve should draw on. Be selective here. A focused set produces focused answers, and adding everything in the matter tends to produce responses that wander.

7. Select any Central Library or research collection sources for Eve to draw from. This step is optional.

8. Click Run Discovery Response Agent.

What to Select as Case Documents

The documents Eve uses to answer the propounded discovery requests:

• Case background. The consult notes, intake summary, or data sheet establishing the facts and the causes of action.

• The evidence the requests are actually about. Medical records for damages interrogatories, the incident report for liability, employment records for a wage claim.

• Prior correspondence with opposing counsel, where earlier positions or agreements affect how something should be answered.

Leave out anything that does not bear on the requests. Unrelated documents do not make the draft more thorough; they dilute it.

Combined Discovery Requests

When the opposing party serves several types in one document, train one discovery response agent that contains each type you need. Eve then returns a single document with all of the responses in it, rather than one pass per type.

Reviewing the Draft

Responses appear in the draft view, where they can be edited directly. Changes can also be requested in place, so revising a single answer does not mean rebuilding the set.

Check the citations on anything factual. A response that states a date, a treatment, a dollar figure, or a fact about the incident should trace back to a document. Open the source on anything that will be relied on.

Nothing here is filed work product until an attorney has made it so. Verification and privilege review are still the attorney's, and the draft exists to get past assembly, not past judgment.