Discovery responses drafted early in the response period, against a date your team sets
Written discovery arrives in sets of interrogatories, requests for production and requests for admission. Responses are generally due 30 days after service, and the rule that applies or an agreed or court-ordered extension sets the actual date. Under both the federal rules and the Texas rules, late admissions can be deemed admitted and late objections waived. The agent turns each set into a response table with proposed objections and a client questionnaire early in the response period, so your associate spends the remaining time on the judgment calls.
Examples use invented names and figures.
What the agent does
- Step 1Parses the set
Every request goes into a response table with its number and text. The agent calculates the response date from the service date and method for your docketing clerk to confirm in the calendar.
- Step 2Proposes objections
Objections come from your firm's own objection bank, request by request, with the reason for each. Texas Rule 193.2(e) waives an objection obscured by numerous unfounded ones unless the court excuses the waiver for good cause, so the agent proposes only the objections a request supports.
- Step 3Asks the client
A plain-language questionnaire built from the interrogatories and the document requests, in English or Spanish, so answers and documents come back in a form the team can use.
- Step 4Drafts the responses
Responses are drafted from the client's answers and the case file, with Bates numbers cited. Where a request draws an objection, the draft states whether anything is being withheld, as Federal Rule 34(b)(2)(C) requires.
Objection strategy and privilege calls stay with the attorney, along with every decision about what is produced. The attorney signs the responses, which certifies a reasonable inquiry under Federal Rule 26(g), and the client verifies the interrogatory answers. The agent never serves or files anything.
- Days before the deadline the first full draft is ready
- Associate and paralegal hours per set
- Objections the reviewing attorney removed or added
- Extensions requested because a draft ran late
Questions about this agent
Does it know the Texas and federal rules?
It works from the rules and orders you set for each matter, such as the Texas Rules of Civil Procedure or a federal scheduling order that changes the dates. Your docketing clerk confirms every date, and your existing rules-based calendar stays the system of record.
Does it serve or file anything?
No. It drafts, and an attorney reviews and signs before anything is served. The client verifies the interrogatory answers. California's 2026 guidance on agentic AI names discovery responses as an example and requires meaningful attorney supervision, which is how we build it in every state.
Can it use the responses we have served before?
Yes. Your objection bank and the responses you served in similar cases are the starting point for its drafts. Before go-live we run it on closed sets inside your systems, since closed files carry the same confidentiality duties as live ones, and compare its drafts with what your team actually served.