Workflow template for legal and contracts
Discovery requests and commitments register
Through discovery, the litigation paralegal keeps one register for the handling attorney: each request and its response in the exact words served, the Bates ranges produced against it, every supplement promised in correspondence with its date as written, and the promises now overdue. The attorney decides what it means.
This workflow template prepares legal work for a lawyer to review. It gives no legal advice and has not been reviewed by a lawyer. A lawyer decides and signs.
Listed under
Add it to a workflow in the Fully Powered Planner, beside the teams and roles that will run it. Book a fit call
The outcome
The handling attorney opens one register and sees the whole written discovery on a matter, request by request. Each request is quoted with its page, and under it every response, amended and supplemental ones included, word for word with the date served. Then come the productions logged against it with their Bates ranges, every promise of more documents or an amended response made in a letter, an email or on a call, and every passage about narrowing what the request covers, each with the side that wrote it. A short list at the end shows the promised supplements whose stated date has passed with nothing recorded since. The promise someone made on a call six weeks ago is on the page, with the words used and whether the other side ever put it in writing.
What it does not do. It gives no legal advice. It decides nothing about legal meaning, merit, validity, privilege, conflicts or deadlines. It sends, files, signs and calendars nothing. It quotes and locates; it never characterises. Nothing is called deficient, evasive, late, misconduct or bad faith, and it never says whether a response or a production is complete. It writes no deficiency argument, proposed order, conferral letter, follow-up email or motion, even for the attorney to edit. It counts no deadline: a promised date is copied exactly as written, and words like "within two weeks" are left uncounted for the attorney. It names no case, statute or rule from memory; one quoted in a paper is copied as written, marked to be verified by the lawyer and given its own line for the attorney. Everything it prepares is a draft for the handling attorney, with a line for each point the attorney must confirm.
Who starts the work, and when
The litigation paralegal or litigation support specialist runs it while written discovery is under way: after responses are served, after each production, after each conferral letter, email or call, and before the attorney's regular look at the matter. The handling attorney decides and signs. In a company's legal team that is the in-house counsel handling the case. In a company with no lawyer of its own, the register is prepared for outside counsel on the case and goes to that counsel, never to the business as an answer.
It is not for a records request sent to a client during an advisory engagement: client document request tracker does that work.
What they supply
- The request: the matter, the case number, the party you act for, the handling attorney, the as-of date, the request sets to include, and any entries the attorney has closed.
- The request sets and the responses, as served, every page, with each certificate of service. Amended and supplemental responses too.
- The production log, as a spreadsheet, one row per production volume, with the Bates range and the requests the cover letter names. If a column heading does not match, it stops and asks which column holds what.
- The correspondence and notes: every letter and email between the parties about the requests, and your own notes of calls and meetings, each with its date and the people on it.
The workflow template reads nothing else: no court rules, nothing remembered, nothing from another matter. It reads the production log, not the documents produced.
What comes out
One draft register, headed as a draft for the handling attorney:
- Request by request: each request and its responses in their own words, with page and date served, the productions logged against it, the promises and passages about scope, and whether the attorney has closed it.
- Promises in correspondence: each promise of further documents, an amended or supplemental response or a privilege log, in the words used, with where it was made, whether it is in a document from the promising side or only in your own call note, the date exactly as stated, any condition in the wording, and what has been recorded since.
- Conferral history: every letter, email, call and meeting in date order, with the passages about each request quoted.
- Promised supplements now overdue: each promise with a stated calendar date before the as-of date and nothing recorded against the request since, listed by the party that made it, with any later production whose cover letter names no request.
- Items still open, and anything not tied to a request, such as a production volume whose cover letter names none.
- Attorney to confirm: a line for each promise, each scope question, each closure and each loose end, ending with the line that leaves every judgement about the responses, and any follow-up, to the attorney.
- Check: the counts, and a sum proving every promise has exactly one standing.
The paralegal checks each quotation, page and Bates range against the papers and gives the register to the handling attorney. The attorney answers each line and decides whether anything follows. Any letter, call or motion is the attorney's, and people write and send it. The register stays in the matter file; it is not for the client or the other side.
An invented example
Illustrative example with invented data. Ashgrove Vell LLP, Strand Merrow LLP, their people, Tessaly Boatworks Ltd, Ormond Vale Coatings Inc., the District Court of Northmarch, the case, the requests, the responses, the production log, the correspondence below and the rule it cites are all invented. No real court, firm, company, person, case or rule is named.
The paralegal's five inputs come first, in full, then what the workflow template prepares. Page breaks in the served papers are shown as [page n].
Input 1: the request
Sent by Odile Farrant, paralegal, on Wednesday 6 May 2026.
Tessaly v. Ormond Vale: please bring the discovery register up to date
as of 6 May 2026 for Caspian.
Matter: Tessaly Boatworks Ltd v. Ormond Vale Coatings Inc., Case No.
NM-CV-26-01183, District Court of Northmarch. We act for Tessaly
Boatworks Ltd, the plaintiff.
Handling attorney: Caspian Rook.
Set to include: our First Set of Requests for Production to Ormond Vale
(code RFP1), with Ormond Vale's responses.
Attached: the request set, the responses, our production log, and the
correspondence and call notes L1 to L4.
Closures: Caspian marked RFP1-1 closed on 21 April 2026.
Odile Farrant, paralegal
Input 2: the request set, as served
[page 1]
DISTRICT COURT OF NORTHMARCH
Tessaly Boatworks Ltd, Plaintiff, v. Ormond Vale Coatings Inc., Defendant.
Case No. NM-CV-26-01183
PLAINTIFF TESSALY BOATWORKS LTD'S FIRST SET OF REQUESTS FOR PRODUCTION
TO DEFENDANT ORMOND VALE COATINGS INC.
Plaintiff Tessaly Boatworks Ltd requests that Defendant Ormond Vale
Coatings Inc. produce the documents described below.
[page 2]
DEFINITIONS AND INSTRUCTIONS
1. "Defendant" means Ormond Vale Coatings Inc.
2. "Document" includes electronically stored information.
3. "Marine primer" means the product sold by Defendant as Vale Marine
Primer.
[page 3]
REQUESTS
REQUEST NO. 1: All purchase orders issued by Tessaly Boatworks Ltd to
Ormond Vale Coatings Inc. for marine primer between January 1, 2024 and
June 30, 2025.
REQUEST NO. 2: All communications between Ormond Vale Coatings Inc. and
any supplier of resin concerning batch numbers 7741 through 7760.
[page 4]
REQUEST NO. 3: All test reports for marine primer batch numbers 7741
through 7760.
REQUEST NO. 4: All documents concerning complaints received by Ormond
Vale Coatings Inc. about adhesion failure of marine primer from January
1, 2023 to the present.
[page 5]
Ashgrove Vell LLP, by Caspian Rook, attorneys for Plaintiff.
CERTIFICATE OF SERVICE
I certify that this document was served on counsel for Defendant on 9
February 2026 by email.
Odile Farrant
Input 3: the responses, as served
[page 1]
DISTRICT COURT OF NORTHMARCH
Tessaly Boatworks Ltd, Plaintiff, v. Ormond Vale Coatings Inc., Defendant.
Case No. NM-CV-26-01183
DEFENDANT ORMOND VALE COATINGS INC.'S RESPONSES AND OBJECTIONS TO
PLAINTIFF'S FIRST SET OF REQUESTS FOR PRODUCTION
[page 2]
GENERAL OBJECTIONS
Defendant objects to each Request to the extent it seeks documents
protected by the attorney-client privilege or the work-product doctrine.
[page 3]
RESPONSE TO REQUEST NO. 1: Defendant will produce responsive purchase
orders in its possession, custody or control.
RESPONSE TO REQUEST NO. 2: Defendant objects that this Request names
no custodian. Notwithstanding that objection, Defendant will produce
the non-privileged communications with its resin suppliers about batch
numbers 7741 through 7760 that a reasonable search locates.
[page 4]
RESPONSE TO REQUEST NO. 3: Reserving the General Objections, Defendant
will produce the test reports it holds for the batches identified.
RESPONSE TO REQUEST NO. 4: Defendant objects that the period of this
Request, which begins in January 2023, is longer than the dispute
warrants. Defendant will not produce documents in response to this
Request.
[page 5]
Strand Merrow LLP, by Hester Lowry, attorneys for Defendant.
CERTIFICATE OF SERVICE
I certify that this document was served on counsel for Plaintiff on 11
March 2026 by email.
Hester Lowry
Input 4: the production log
Tessaly v. Ormond Vale · Production log · updated 5 May 2026
Volume | Date Produced | Produced By | Bates Start | Bates End | Against Requests | Cover Letter
OVC-VOL001 | 2026-03-20 | Ormond Vale Coatings | OVC000001 | OVC000214 | RFP1-1 | Strand Merrow letter, 2026-03-20
OVC-VOL002 | 2026-04-17 | Ormond Vale Coatings | OVC000215 | OVC000388 | RFP1-3 | Strand Merrow letter, 2026-04-17
OVC-VOL003 | 2026-04-24 | Ormond Vale Coatings | OVC000389 | OVC000402 | | Strand Merrow email, 2026-04-24
Input 5: the correspondence and notes
L1 · Letter · 27 March 2026
From Caspian Rook, Ashgrove Vell LLP, to Hester Lowry, Strand Merrow LLP
[page 1]
Dear Ms Lowry,
Tessaly Boatworks Ltd v. Ormond Vale Coatings Inc., Case No.
NM-CV-26-01183
1. We write about your client's responses of 11 March 2026 to our
client's First Set of Requests for Production.
2. Your client's response to Request No. 2 says that it will produce
the communications 'that a reasonable search locates.' Please tell us
whose files that search covers.
3. Your client's response to Request No. 4 says that no documents will
be produced. We would like to discuss whether a shorter period would
resolve your client's objection. Please let us know when you are free
for a call in the week of 6 April.
Yours sincerely,
Caspian Rook
Ashgrove Vell LLP
L2 · Note of a video call · 8 April 2026
Written by Caspian Rook, Ashgrove Vell LLP
Participants: Caspian Rook and Odile Farrant (Ashgrove Vell LLP); Hester
Lowry (Strand Merrow LLP).
1. RFP 2: HL said the supplier emails sit with the purchasing team and
are being collected now. HL said Ormond Vale will produce the supplier
communications by April 30, 2026.
2. RFP 3: HL said the test reports would be produced the following week.
3. RFP 4: We proposed limiting the request to complaints received from
1 January 2024. HL agreed to that period. HL said Ormond Vale will
produce complaint records for that period if its client approves the
cost of collection.
4. RFP 1: HL said every purchase order is in the first volume.
L3 · Email · 10 April 2026, 16:42
From Hester Lowry, Strand Merrow LLP, to Caspian Rook, copy Odile
Farrant, Ashgrove Vell LLP
Subject: Tessaly v. Ormond Vale: RFP follow-up
Caspian,
Following our call on Wednesday: Ormond Vale will produce the resin
supplier communications responsive to Request No. 2 by April 30, 2026.
We will also serve an amended response to Request No. 4 within two
weeks. We have not agreed to any change in the period for Request No.
4; we said we would take your proposal to our client.
As to Request No. 3, Rule NM-418 of the Northmarch Rules of Civil
Procedure gives Ormond Vale until the close of fact discovery to
complete its production.
Hester
L4 · Email · 1 May 2026, 09:15
From Hester Lowry, Strand Merrow LLP, to Caspian Rook, Ashgrove Vell LLP
Subject: Tessaly v. Ormond Vale: test reports
Caspian,
Ormond Vale will produce the remaining test reports for batches 7755
through 7760, responsive to Request No. 3, by May 15, 2026.
Hester
What the workflow template prepares
DRAFT DISCOVERY REGISTER · FOR THE HANDLING ATTORNEY TO REVIEW
Not legal advice. Nothing is decided about legal meaning, merit,
validity, privilege, conflicts or deadlines, and nothing is said about
whether any response, objection or production is complete, adequate or
deficient. No deadline is counted.
Nothing has been sent, served, filed, signed or calendared.
Matter: Tessaly Boatworks Ltd v. Ormond Vale Coatings Inc.,
NM-CV-26-01183, District Court of Northmarch
Register as of: 2026-05-06
Prepared for: Caspian Rook, handling attorney, to review
Run by: Odile Farrant, paralegal
PAPERS READ
- Request set RFP1: Plaintiff Tessaly Boatworks Ltd's First Set of
Requests for Production to Defendant Ormond Vale Coatings Inc., served
by Tessaly Boatworks Ltd on Ormond Vale Coatings Inc., served
2026-02-09 by email as its certificate of service states, 4 requests,
5 pages; definitions and instructions on p. 2
- Response to RFP1: Defendant Ormond Vale Coatings Inc.'s Responses and
Objections to Plaintiff's First Set of Requests for Production, served
2026-03-11 by email as its certificate of service states, 5 pages
- Production log: Tessaly v. Ormond Vale · Production log · updated
5 May 2026, 3 rows
- Correspondence and notes: 4 items, L1 to L4, 2026-03-27 to 2026-05-01
- Attorney's closures: 1, as relayed in the request
A. REQUEST-BY-REQUEST REGISTER
RFP1-1 · RFP1 No. 1 · served by Tessaly Boatworks Ltd on Ormond Vale
Coatings Inc.
Request (RFP1, p. 3): "All purchase orders issued by Tessaly Boatworks
Ltd to Ormond Vale Coatings Inc. for marine primer between January
1, 2024 and June 30, 2025."
Response (Responses to RFP1, served 2026-03-11, p. 3):
"Defendant will produce responsive purchase orders in its
possession, custody or control."
General objections: Responses to RFP1, p. 2, not repeated here.
Produced against it, as the production log records:
- OVC-VOL001, OVC000001 to OVC000214, produced 2026-03-20 by Ormond
Vale Coatings, cover Strand Merrow letter, 2026-03-20
Promises in correspondence: None recorded.
Correspondence naming it: L2.
Scope passages:
- None.
Open: No, closed by Caspian Rook on 2026-04-21, as relayed in the
request
RFP1-2 · RFP1 No. 2 · served by Tessaly Boatworks Ltd on Ormond Vale
Coatings Inc.
Request (RFP1, p. 3): "All communications between Ormond Vale Coatings
Inc. and any supplier of resin concerning batch numbers 7741 through
7760."
Response (Responses to RFP1, served 2026-03-11, p. 3):
"Defendant objects that this Request names no custodian.
Notwithstanding that objection, Defendant will produce the
non-privileged communications with its resin suppliers about batch
numbers 7741 through 7760 that a reasonable search locates."
General objections: Responses to RFP1, p. 2, not repeated here.
Produced against it, as the production log records:
- None recorded.
Promises in correspondence: P1, P4.
Correspondence naming it: L1, L2, L3.
Scope passages:
- None.
Open: Yes
RFP1-3 · RFP1 No. 3 · served by Tessaly Boatworks Ltd on Ormond Vale
Coatings Inc.
Request (RFP1, p. 4): "All test reports for marine primer batch
numbers 7741 through 7760."
Response (Responses to RFP1, served 2026-03-11, p. 4):
"Reserving the General Objections, Defendant will produce the test
reports it holds for the batches identified."
General objections: Responses to RFP1, p. 2, not repeated here.
Produced against it, as the production log records:
- OVC-VOL002, OVC000215 to OVC000388, produced 2026-04-17 by Ormond
Vale Coatings, cover Strand Merrow letter, 2026-04-17
Promises in correspondence: P2, P6.
Correspondence naming it: L2, L3, L4.
Scope passages:
- None.
Open: Yes
RFP1-4 · RFP1 No. 4 · served by Tessaly Boatworks Ltd on Ormond Vale
Coatings Inc.
Request (RFP1, p. 4): "All documents concerning complaints received by
Ormond Vale Coatings Inc. about adhesion failure of marine primer
from January 1, 2023 to the present."
Response (Responses to RFP1, served 2026-03-11, p. 4):
"Defendant objects that the period of this Request, which begins in
January 2023, is longer than the dispute warrants. Defendant will
not produce documents in response to this Request."
General objections: Responses to RFP1, p. 2, not repeated here.
Produced against it, as the production log records:
- None recorded.
Promises in correspondence: P3, P5.
Correspondence naming it: L1, L2, L3.
Scope passages:
- L1 (Ashgrove Vell LLP, p. 1, para. 3): "We would like to discuss
whether a shorter period would resolve your client's objection."
- L2 (Ashgrove Vell LLP, point 3): "We proposed limiting the request
to complaints received from 1 January 2024. HL agreed to that
period."
- L3 (Strand Merrow LLP, para. 2): "We have not agreed to any change
in the period for Request No. 4; we said we would take your
proposal to our client."
Open: Yes
B. PROMISES IN CORRESPONDENCE
P1 · RFP1-2 · promised by Ormond Vale Coatings Inc. · L2, 2026-04-08,
note of a video call, written by Caspian Rook
Words: "HL said Ormond Vale will produce the supplier communications by
April 30, 2026." (L2, point 1)
In a document written by the promising party's side: No: a note
written by our side
Date as stated: "by April 30, 2026" → 2026-04-30
Wording: no condition
Recorded against RFP1-2 on or after 2026-04-08: nothing
Standing: Stated date has passed; nothing recorded since: overdue (D1)
P2 · RFP1-3 · promised by Ormond Vale Coatings Inc. · L2, 2026-04-08,
note of a video call, written by Caspian Rook
Words: "HL said the test reports would be produced the following
week." (L2, point 2)
In a document written by the promising party's side: No: a note
written by our side
Date as stated: "the following week" → not a calendar date: not
counted
Wording: no condition
Recorded against RFP1-3 on or after 2026-04-08: OVC-VOL002, OVC000215
to OVC000388, produced 2026-04-17
Standing: Something recorded since: attorney to decide whether it is
what was promised
P3 · RFP1-4 · promised by Ormond Vale Coatings Inc. · L2, 2026-04-08,
note of a video call, written by Caspian Rook
Words: "HL said Ormond Vale will produce complaint records for that
period if its client approves the cost of collection." (L2, point 3)
In a document written by the promising party's side: No: a note
written by our side
Date as stated: none stated
Wording: with a condition or intention ("if")
Recorded against RFP1-4 on or after 2026-04-08: nothing
Standing: Worded with a condition or intention: attorney to decide
P4 · RFP1-2 · promised by Ormond Vale Coatings Inc. · L3, 2026-04-10,
email, from Hester Lowry
Words: "Following our call on Wednesday: Ormond Vale will produce the
resin supplier communications responsive to Request No. 2 by April
30, 2026." (L3, para. 1)
In a document written by the promising party's side: Yes
Date as stated: "by April 30, 2026" → 2026-04-30
Wording: no condition
Recorded against RFP1-2 on or after 2026-04-10: nothing
Standing: Stated date has passed; nothing recorded since: overdue (D2)
P5 · RFP1-4 · promised by Ormond Vale Coatings Inc. · L3, 2026-04-10,
email, from Hester Lowry
Words: "We will also serve an amended response to Request No. 4 within
two weeks." (L3, para. 2)
In a document written by the promising party's side: Yes
Date as stated: "within two weeks" → not a calendar date: not counted
Wording: no condition
Recorded against RFP1-4 on or after 2026-04-10: nothing
Standing: No calendar date stated: not counted; attorney to decide
P6 · RFP1-3 · promised by Ormond Vale Coatings Inc. · L4, 2026-05-01,
email, from Hester Lowry
Words: "Ormond Vale will produce the remaining test reports for batches
7755 through 7760, responsive to Request No. 3, by May 15, 2026."
(L4, para. 1)
In a document written by the promising party's side: Yes
Date as stated: "by May 15, 2026" → 2026-05-15
Wording: no condition
Recorded against RFP1-3 on or after 2026-05-01: nothing
Standing: Stated date not yet reached
C. CONFERRAL HISTORY
L1 · 2026-03-27 · letter · Caspian Rook, Ashgrove Vell LLP, to Hester
Lowry, Strand Merrow LLP
- RFP1-2 (p. 1, para. 2): "Your client's response to Request No. 2
says that it will produce the communications 'that a reasonable
search locates.' Please tell us whose files that search covers."
- RFP1-4 (p. 1, para. 3): "Your client's response to Request No. 4
says that no documents will be produced. We would like to discuss
whether a shorter period would resolve your client's objection.
Please let us know when you are free for a call in the week of 6
April."
L2 · 2026-04-08 · video call · participants: Caspian Rook and Odile
Farrant (Ashgrove Vell LLP); Hester Lowry (Strand Merrow LLP); note
written by Caspian Rook
- RFP1-2 (point 1): "RFP 2: HL said the supplier emails sit with the
purchasing team and are being collected now. HL said Ormond Vale
will produce the supplier communications by April 30, 2026."
- RFP1-3 (point 2): "RFP 3: HL said the test reports would be produced
the following week."
- RFP1-4 (point 3): "RFP 4: We proposed limiting the request to
complaints received from 1 January 2024. HL agreed to that period.
HL said Ormond Vale will produce complaint records for that period
if its client approves the cost of collection."
- RFP1-1 (point 4): "RFP 1: HL said every purchase order is in the
first volume."
L3 · 2026-04-10 · email · Hester Lowry, Strand Merrow LLP, to Caspian
Rook, copy Odile Farrant, Ashgrove Vell LLP
- RFP1-2 (para. 1): "Following our call on Wednesday: Ormond Vale will
produce the resin supplier communications responsive to Request No.
2 by April 30, 2026."
- RFP1-4 (para. 2): "We will also serve an amended response to Request
No. 4 within two weeks. We have not agreed to any change in the
period for Request No. 4; we said we would take your proposal to our
client."
- RFP1-3 (para. 3): "As to Request No. 3, Rule NM-418 of the
Northmarch Rules of Civil Procedure gives Ormond Vale until the close
of fact discovery to complete its production." [cites an authority:
to be verified by the lawyer]
L4 · 2026-05-01 · email · Hester Lowry, Strand Merrow LLP, to Caspian
Rook, Ashgrove Vell LLP
- RFP1-3 (para. 1): "Ormond Vale will produce the remaining test
reports for batches 7755 through 7760, responsive to Request No. 3,
by May 15, 2026."
D. PROMISED SUPPLEMENTS NOW OVERDUE · as of 2026-05-06
Stated date before the as-of date, and nothing recorded against the
request on or after the date of the item that holds the promise.
Productions the log ties to no request are in F and are not set
against any promise; each line names those dated on or after the item.
Promised by Tessaly Boatworks Ltd:
- None.
Promised by Ormond Vale Coatings Inc.:
D1. P1 · RFP1-2 · stated date 2026-04-30 · in L2 (note of a video call,
written by Caspian Rook; written by the promising party's side: No).
Nothing recorded against RFP1-2 on or after 2026-04-08.
In F, produced on or after 2026-04-08: F1, OVC-VOL003.
D2. P4 · RFP1-2 · stated date 2026-04-30 · in L3 (email, from Hester
Lowry; written by the promising party's side: Yes).
Nothing recorded against RFP1-2 on or after 2026-04-10.
In F, produced on or after 2026-04-10: F1, OVC-VOL003.
E. ITEMS STILL OPEN
- RFP1-2: P1 overdue (D1); P4 overdue (D2). Produced against it: none
recorded. Scope passages: none.
- RFP1-3: P2 something recorded since: attorney to decide; P6 stated
date not yet reached. Produced against it: OVC-VOL002. Scope
passages: none.
- RFP1-4: P3 worded with a condition or intention: attorney to decide;
P5 no calendar date stated: attorney to decide. Produced against it:
none recorded. Scope passages: L1, L2, L3.
Closed by the attorney: RFP1-1 (Caspian Rook, 2026-04-21).
F. NOT TIED TO A REQUEST
F1. Production OVC-VOL003, OVC000389 to OVC000402, produced 2026-04-24
by Ormond Vale Coatings: the production log names no request.
HANDLING ATTORNEY TO CONFIRM
[ ] RFP1-1: closed by Caspian Rook on 2026-04-21, as relayed in the
request. Confirm: ____
[ ] P1 / D1, RFP1-2: promise recorded in Caspian Rook's note of the
2026-04-08 video call, stated date 2026-04-30; nothing recorded
against RFP1-2 on or after 2026-04-08 (OVC-VOL003, in F, was
produced 2026-04-24). Confirm: ____
[ ] P2, RFP1-3: "the following week", not counted; OVC-VOL002
(OVC000215 to OVC000388) produced against RFP1-3 on 2026-04-17.
Whether it is what was promised. Decide: ____
[ ] P3, RFP1-4: worded with a condition ("if"), no date stated; nothing
recorded against RFP1-4 on or after 2026-04-08. Decide: ____
[ ] P4 / D2, RFP1-2: promise in Hester Lowry's email of 2026-04-10,
stated date 2026-04-30; nothing recorded against RFP1-2 on or after
2026-04-10 (OVC-VOL003, in F, was produced 2026-04-24). Confirm: ____
[ ] P5, RFP1-4: "within two weeks", not counted; nothing recorded
against RFP1-4 on or after 2026-04-10. Decide: ____
[ ] P6, RFP1-3: stated date 2026-05-15, not yet reached; nothing
recorded against RFP1-3 on or after 2026-05-01. Confirm: ____
[ ] RFP1-4, scope: passages in L1, L2, L3. Whether any change to what
RFP1-4 covers was agreed. Decide: ____
[ ] F1: OVC-VOL003 (OVC000389 to OVC000402), produced 2026-04-24, names
no request in the production log. Which entry, if any. Supply: ____
[ ] Authority cited in L3 (para. 3): "Rule NM-418 of the Northmarch
Rules of Civil Procedure". Not checked or relied on in this
register; to be verified by the lawyer. Confirm: ____
[ ] The requests and responses above are copied as served. Whether
any response, objection or production is complete, adequate or
deficient, and whether there is any follow-up, conferral letter or
motion, is the handling attorney's decision. Confirm: ____
[ ] Register reviewed. Reviewed by: ____ Date: ____
CHECK
- Requests in the sets: 4. Entries in A: 4.
- Responses: 4 entries with a response; 0 with none in the papers
supplied.
- Production log: 3 rows; 2 tied to an entry; 1 in F.
- Correspondence: 4 items read; 10 passages quoted in C; 3 scope
passages; 0 passages in F.
- Promise lines: 6 = 0 closed (S1) + 1 something recorded since (S2) +
1 condition or intention (S3) + 1 no calendar date (S4) + 2 overdue
(S5) + 1 not yet reached (S6).
- No date was counted and no deadline stated. Dates are copied as
written; dates with a day, month and year are written YYYY-MM-DD.
Reviewed by: ____________ Date: ________
Until the handling attorney reviews it, this is a draft.
Four points the example shows. The promise to produce the supplier communications appears twice, once in the attorney's own note of the call and once in the other side's email, and each is its own line, so the attorney can see which one the other side put in writing. And the call note records that a shorter period for Request No. 4 was agreed, while the other side's email says it was not: the register quotes both and leaves the question to the attorney. Each overdue line in section D names OVC-VOL003, the production whose cover email names no request, so an attorney reading the overdue list alone still sees it, without the register saying whether it is what was promised. And the rule cited in the 10 April email is quoted as written, marked to be verified by the lawyer and given its own line, never checked or relied on.
Where it fits
- Legal and contracts: discovery is litigation work the legal team owns, and this register keeps its record, request by request, for the attorney who decides.
- Law firms, in litigation groups where several request sets run at once and a promise made on a call is easy to lose by the following month.
- Insurance, where claims litigation runs through outside firms and in-house counsel wants each matter's discovery record in the same shape.
- Manufacturing, where product and supply disputes bring requests for batch records, test reports and supplier correspondence that arrive across many productions.
- Established businesses, where one experienced paralegal keeps the discovery record in a spreadsheet nobody else can read.
- Growth & scaling, when the matters in discovery grow faster than the litigation support team.
It sits beside deposition transcript summary and privilege log entry check in a litigation team's discovery work. Dates set in a court order belong to court-order deadline notice preparation, not to this register.
What has to change for your company
The production log is yours, and it is the heart of this. Decide who keeps it, what its columns are called, and the rule that it records only the requests a cover letter names, never anyone's view of what a production answers. Decide which notes of calls and meetings go in with the correspondence and who writes them, how the attorney records that an entry is closed, and where the register is kept in the matter file and who may read it, since it holds your own notes of calls. If the firm already numbers its discovery its own way, set those codes once and keep them on every run.
We sit with the paralegal who keeps your discovery record and the attorney who relies on it, write down how it is really kept, and set it up in the AI product the firm has approved: ChatGPT, Claude, Copilot or Gemini. Confirm with your own policies, and with counsel on any protective order, that the papers may be used there.
What has been checked
Fully Powered AI wrote this workflow template in its own words, drawing on a published discovery tracking method credited in its sources, with that method's deficiency findings, proposed cures, sanctions flags and deadline counting taken out. It was editorially reviewed on 11 November 2026. It has not been reviewed by a lawyer. It was tried once on its invented example in Claude on 11 November 2026, and the record of that run, which replaced two earlier ones from the same day, is published with the template. It has not yet been tested in a client environment, and it has not yet been tested as a packaged version in ChatGPT, Claude, Copilot or Gemini.
Testing at your firm means running it on a past matter whose discovery your attorney already knows, with hard cases planted in advance: a response that answers two requests together, an amended response, a promise made only on a call, the same promise repeated in an email, "within two weeks", a promise with a condition, a production whose cover letter names no request, and a request to say whether a response is deficient. The paralegal checks every quotation and date against the papers before the attorney relies on it. Pilot acceptance-test preparation builds that set, and what we test before we call an AI workflow ready describes the record we keep.
Who decides
Your people keep
- Whether a response or a production is complete
- Whether a change to what a request covers was agreed
- Whether anything follows, and any letter, call or motion
- Which entries are closed
It does not
- Gives no legal advice
- Decides nothing about legal meaning, merit, validity, privilege, conflicts or deadlines
- Sends, files, signs and calendars nothing
- Never calls a response deficient, evasive or late
- Counts no deadline
- Writes no deficiency argument, proposed order, conferral letter or motion
Questions people ask
Who is it for?
The litigation paralegal or litigation support specialist runs it while written discovery is under way, and the handling attorney decides and signs. In a company with no lawyer of its own, the register goes to outside counsel on the case.
What do I need to supply?
The request, with the matter, the as-of date and the handling attorney. The request sets and every response, as served, every page. The production log as a spreadsheet. The correspondence, and your own notes of calls and meetings.
What does it not do?
It gives no legal advice. It decides nothing about legal meaning, merit, validity, privilege, conflicts or deadlines. It sends, files, signs and calendars nothing. Nothing is called deficient or late, no deadline is counted, and no letter or motion is written.
What do I get?
One draft register for the handling attorney: each request and its responses in their own words, with page and date served, the productions logged against it, every promise with its date as stated, the conferral history, the promised supplements now overdue and a line for each point to confirm.
What has been checked?
It was editorially reviewed and tried once on its invented example in Claude. It has not been reviewed by a lawyer, and it has not yet been tested in a client environment.
The full workflow template
Everything above is the outline. The complete workflow template is the working version: the roles, the inputs, the procedure, the exceptions and stop conditions, the output format, the reviewer checklist, the acceptance tests, the instructions for an AI assistant and what to customize for your company. It comes with a download and the link to its folder in Fully Powered’s public repository.
Free with an account. Sign in by email: no password and no card.
Next step
Put this workflow template to work for your team: on your plan, or built with you in a sprint.
Build this in a sprint
In a sprint, Fully Powered adapts this workflow template to your rules, proves it on your own work and puts it in the hands of the roles that own it.
Two ways to begin: