5 minutes

How to Use AI to Respond to Discovery

This blog post will delve into how AI can assist attorneys in responding to discovery with unprecedented efficiency. Legal professionals users are turning this 8 hour response process into 45 minutes of work with A.
Written by
Jamie Fonarev
Published on
July 18, 2024


In the intricate dance of litigation, responding to discovery requests is a pivotal yet time-consuming step that can significantly impact the outcome of a case. Traditionally, legal teams have had to manually sift through mountains of documents, meticulously analyze each request, and craft responses that are both strategic and compliant with legal standards. This process is not only labor-intensive but also prone to human error, often resulting in long hours and delayed timelines. Responding to a set of 15 interrogatories could take up to 8 hours of a lawyer's time, often longer as they gather information from the client to supplement answers. 

This blog post will delve into how AI can assist attorneys in responding to discovery with unprecedented efficiency. By leveraging AI, attorneys can quickly upload relevant case documents, set precise instructions for their AI assistant, and generate responses that are both thorough and tailored to the specific nuances of their cases. Legal professionals are turning an 8 hour response process into 45 minutes of work with AI, saving time and headache, and delighting their clients along the way. Join us as we explore the transformative power of AI in labor and employment law, and learn how to leverage it to its fullest potential for the benefit of your clients.

The Role of AI in Efficiently Responding to Discovery

AI is revolutionizing the way legal professionals tackle the demanding task of discovery. By automating the sifting, sorting, and analysis of vast quantities of documents, AI is not just a tool but a game-changer, enabling attorneys to respond to discovery requests with a speed and accuracy that far surpasses traditional methods. In labor and employment law, where the stakes are high and the paperwork is plentiful, AI's ability to quickly identify relevant case information and draft precise responses is invaluable. It allows lawyers to focus on crafting a strategic narrative for their cases, confident that the foundational work of discovery is being handled with meticulous care.

Step 1: Preparing Your AI for the Task

Before using AI to respond to discovery, it is essential to give your AI platform what it needs to successfully help you with this task. This preparatory step is what the AI will build on, making sure that the responses it generates are precise, relevant, and strategically aligned with your case goals. Here's the roadmap to get you ready:

Uploading Comprehensive Documents

The efficacy of AI in crafting discovery responses is contingent upon the breadth and depth of the information it has to work with. Start by compiling a comprehensive set of documents pertinent to your case—this may include pleadings, key evidence, client interviews, and any other material that provides context to the dispute at hand.

Of course you'll also upload the discovery requests that were propounded on you. 

By uploading both the questions and the information that you have to supply the answers, you're going to give the AI the database of information it would need to complete your requests. Make sure that you have 

Setting Up AI "Instructions" for a Tailored Experience

AI platforms excel when their capabilities are directed with clear and precise instructions, much like guiding a junior associate with a comprehensive brief. This clarity is essential to align the AI's functionality with the specific objectives of the discovery process. By providing detailed instructions, attorneys can ensure that the AI's responses to discovery requests are focused, relevant, and strategically sound.

For AI platforms not inherently tailored for legal tasks, the importance of detailed instructions becomes even more critical. Providing rich contextual information within these instructions is key to refining the AI's output, thereby ensuring that the responses to discovery are of the highest quality and closely adhere to the nuances of the legal matter at hand.

Consider this template for AI instructions tailored to propounding discovery:

"I am Jim Johnson, an attorney at Eve Law. Eve Law is one of the most prominent and competent California Employment Law firms that represents plaintiffs in litigation against their employers.

You are a sophisticated legal assistant with expertise in the discovery response processes. Your task is to assist in drafting discovery responses that are comprehensive, precise, and strategically targeted. Analyze the case files I have uploaded, and generate discovery requests that are directly relevant to the legal issues and factual circumstances of this case. Your output should be methodical, well-organized, and reflect a deep understanding of the discovery goals we aim to achieve."

 Your instructions should encapsulate these key elements:

  1. A brief introduction to your firm and its approach to discovery.

  2. A description of the desired AI persona (e.g., a detail-oriented discovery specialist).

  3. A clear directive on the role the AI should fulfill, including the types of discovery documents to generate and the specific information to focus on.

If you have a particular cause of action you are pursuing, you can even help narrow the focus of the AI. For example, you could add the following sentence to your instructions: 

"Your output should focus on helping us support our claims of wrongful termination."

By providing the AI with clear instructions, you set a clear path for it to follow, ensuring that the discovery documents it produces are in harmony with your firm's standards and the strategic direction of your case. This preparation is the cornerstone of a streamlined and effective discovery propounding process.

Step 2: Have Eve Respond To Discovery

With the groundwork laid through comprehensive document uploads, the second step involves directly engaging the AI to craft responses to the discovery requests. There is no right or wrong way to do this - simply ask as you would another team member helping you on the case. 

💬 Example Message: I have provided you with discovery requests served to us by the defense in this litigation. I need you to analyze every request individually. For each individual request first decide if we have grounds to object to their request, if we do fill in our reply stating the objection and the reasoning. If we have no grounds to object, decide if we have enough information to answer the request, if yes fill in our answer, if no fill in with a denotation that we will need to have the client fill in that answer. Provide the defense discovery request documents back to me with your answers filled in as outlined above. provide each document in a code block.

 You can send a comprehensive message as above, or break it up into smaller sections. If you have many responses to complete, we recommend breaking the task up. For example, ask the AI to fill out the responses for questions 1-5. then iterate on those responses (see below in step 3). Then move on to questions 6-10, and so on. 

Step 3: Re-drafting responses (as needed)

After the AI has provided initial drafts of the discovery responses, the next step is to refine and perfect them. This iterative process allows for the fine-tuning of each response to ensure they meet the legal and strategic standards of the case. Attorneys should review the AI-generated responses for precision, relevance, and potential areas where objections could be raised or answers could be strengthened.

💬 Example Message: Can you respond again, but make sure that you are prioritizing making objections. Go through these responses and find any other areas that we could raise an objection to.

By engaging in this iterative process, attorneys can hone their discovery responses to be clear, concise, and compelling, thereby enhancing their position in the litigation. 


The integration of AI into the discovery response process marks a significant advancement in legal practice, offering labor and employment attorneys a powerful tool to enhance efficiency and accuracy. By following the outlined steps—uploading key documents, setting precise instructions, and iteratively refining responses—attorneys can transform the traditionally time-consuming task of responding to discovery into a streamlined operation. This not only saves valuable time but also allows attorneys to focus on the strategic aspects of their cases. As we continue to embrace technological innovations, AI stands as a testament to the evolving landscape of legal services, promising a future where legal professionals can allocate their expertise where it matters most.

The integration of AI into the process of propounding is just one transformative step, stay tuned for more content on how to leverage AI in the labor and employment case lifecycle.

 Up Next: Analyzing Depositions and Identifying Inconsistencies with AI 

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