Discovery Gap Finder
Flag every evasive, incomplete, or boilerplate-objection answer against what was actually asked — and walk away with your meet-and-confer list drafted.
What is an AI discovery gap finder prompt?
It is a CITE prompt that asks an AI tool to extract specific items from discovery responses. Flag every evasive, incomplete, or boilerplate-objection answer against what was actually asked — and walk away with your meet-and-confer list drafted. You fill in three fields; the Evidence block requires a Bates or page cite for every finding so a person can check each one against the record.
Sample prompt
Synthetic data
Synthetic example: The names, dates, case details, and issues below are fictional CasePrompts sample values, not client data or evidence from a real matter. They demonstrate the prompt format, not the accuracy of any AI model's output.
Preview the complete sample prompt
CONTEXT: You are a litigation support analyst assisting plaintiff's counsel in a construction defect matter. The attached materials are the opposing party's discovery responses, paired with the requests and interrogatories they answer. The issues that matter are: subcontractor scopes of work; water intrusion repairs; notice to the GC. INSTRUCTIONS: Review every request/answer pair in sequence. For each, compare what was asked against what was actually answered, and classify any deficiency as exactly one of: 1. EVASIVE — the answer responds to a different question than the one asked. 2. INCOMPLETE — the answer addresses part of the request and is silent on the rest; identify the unanswered part. 3. BOILERPLATE OBJECTION — objections asserted with no substantive response, or "subject to and without waiving" followed by a non-answer. 4. IMPROPER REFERENCE — answers that point to documents or other responses without identifying them with specificity. Answers that respond fully belong in a separate list, not the deficiency table. Do not argue whether objections are legally valid — identify what was asked and what was not answered. TEMPLATE — format your output exactly as follows: ## Deficiency map | Req # | What was asked (one line) | What was answered (verbatim key language) | Deficiency type | What a complete answer would cover | |---|---|---|---|---| ## Meet-and-confer points Numbered list, one per deficient response, phrased neutrally and ready to paste into a letter, each with the request number. ## Answered in full Request numbers only. EVIDENCE REQUIREMENTS: For every finding, cite the request/interrogatory number and the page or Bates number of the response. Quote the operative answer language verbatim — a response may not be characterized as evasive or incomplete unless its own words support it. If a referenced document or verification page is missing from the production, list it under a final heading "Missing from the production" rather than assuming its contents. Unless a section above specifies its own marker, write "not found in the record" wherever the provided record does not support a requested finding. Do not infer or fill gaps from outside knowledge. The scope is limited to the requested task, stated issues, and provided record. Do not introduce outside subjects or sources. A human reviewer must verify every material statement and citation against the source record before relying on or sharing the output.
Through the Civil / insurance defense lens
Prioritize plaintiff admissions bearing on comparative fault, prior injuries or claims, gaps and lapses in treatment, activities inconsistent with claimed limitations, and mitigation.
Through the Commercial litigation lens
Prioritize admissions about contract formation, performance and non-performance, notice given or not given, and damages quantification — anchored to the documents the witness was shown.
Through the Criminal defense lens
Prioritize inconsistencies among State witnesses, statements bearing on identification reliability and observation conditions, language suggesting suggestive procedures, and references to evidence or recordings not found in the production.
Through the Employment litigation lens
Prioritize testimony establishing decision-maker knowledge and timing, the stated reasons for each employment action, comparator treatment, and departures from written policy.
Through the Family law lens
Prioritize admissions about income, assets, and liabilities, statements about parenting time and conduct, and — where the record preserves it — tone: how something was said to a co-parent often matters as much as what was said.
Through the Medical malpractice — defense lens
Prioritize chart language documenting clinical reasoning and judgment calls, informed-consent discussions, patient non-compliance, and comorbidities bearing on outcome.
Through the Medical malpractice — plaintiff lens
Prioritize testimony and chart language bearing on the applicable standard of care, departures from protocols or orders, and admissions about what should have been done differently.
Through the Personal injury — plaintiff lens
Prioritize testimony establishing notice and fault, admissions about the mechanism of injury, and the human impact of the injuries — pain, limitations, and life disruption in the witness's own words.
Through the Probate & estate litigation lens
Prioritize statements about the decedent's intent, capacity, and dependence; who was present at execution; and how the fiduciary handled the assets — admissions about access and control often decide these cases.
Through the Prosecution lens
Prioritize corroboration across independent sources, spontaneous statements, and testimony establishing each element — and separately flag anything arguably favorable to the defense for disclosure review.
Through the Workers' compensation — claimant lens
Prioritize testimony establishing the accident arose out of and in the course of employment, prompt reporting, and employer knowledge — plus every statement about restrictions and ability to work.
Through the Workers' compensation — employer/carrier lens
Prioritize claimant admissions bearing on course and scope, late or inconsistent reporting, prior injuries or claims to the same body parts, and activities inconsistent with claimed restrictions.
AI output is a starting point, not work product. Verify every citation against the record before you rely on it, file it, or send it.
What you'll fill in
- 01Your role
- 02Case typee.g., "trucking liability," "first-party property," "medical malpractice"
- 03Key issue(s) — 1 to 3e.g., "vehicle speed at impact; brake maintenance; visibility"
Verification checklist
- Discovery responses: open each cited Bates or page location and confirm it supports the finding. The prompt asks: “For every finding, cite the request/interrogatory number and the page or Bates number of the response.”
- Compare every verbatim quotation word for word with the source.
- Re-check every item labelled “Missing from the production” or “not found in the record” against the full source; these labels flag gaps or judgment calls for a person to resolve, not proof of absence.
- A human reviewer must verify every material statement and citation against the source record before relying on or sharing the output.
Pro tip Run it the day responses land — the meet-and-confer clock starts whether or not anyone has read the responses yet.
Related verification workflow
Related templates
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Pull every admission, damaging concession, and 'I don't know' on your key issues out of a transcript — with verbatim Q&A and page:line cites.
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Privilege Log Builder
Turn a set of withheld documents into a privilege log — date, author, recipients, type, and a non-waiving basis for each — with the doubtful calls flagged for review.