discovery-summarization

Summarizes settlement negotiations and agreements in litigation. Extracts key terms, payment structures, release provisions, negotiation chronology, and compliance obligations for both two-party and complex multi-party settlements. Use when the user needs a settlement summary, settlement analysis, negotiation history, or settlement term review.

Produces structured summaries of insurance claims correspondence including coverage letters, reservation of rights (ROR), denial letters, and claim file documents. Extracts policy details, coverage positions, claims chronology, settlement posture, and liability exposure. Use when summarizing claim files, coverage disputes, ROR letters, denial letters, or multi-document insurance correspondence threads.

Produces structured expert witness analyses covering qualifications, opinions, methodology, admissibility (Daubert/Frye), and cross-examination vulnerabilities. Use when evaluating opposing or retained experts during discovery or pre-trial, preparing motions to exclude, or developing cross-examination strategy.

Generates a structured internal e-discovery status report tracking ESI from collection through attorney review. Covers custodian volumes, search term hit rates, review coding statistics, reviewer productivity, and projected timelines. Use when counsel, case managers, or clients need a progress report during the discovery phase of U.S. commercial litigation.

Produces an internal U.S. litigation e-discovery status summary covering ESI collection, processing, search-term hits, review throughput, relevance and privilege rates, and completion forecasts. Triggers when the user requests an e-discovery status report, collection log summary, processing report, review statistics, coding report, search-term results, or privilege review summary.

Drafts court-ready ESI Protocol Agreements governing electronically stored information exchange in U.S. federal litigation. Covers FRCP 26(f)/34 compliance, FRE 502(d) clawback, TAR methodology, privilege logs, and production format specs. Use when drafting e-discovery stipulations, ESI protocols, meet-and-confer agreements, or joint discovery plans.

Produces an attorney-grade audit memorandum assessing whether written discovery responses are legally binding and timely. Use this skill when the user mentions verification audit, discovery verification, proof of service review, signature authority, perjury clause compliance, deadline computation, mailbox rule extensions, service defects, waiver risk, or motion-to-compel deadline analysis. Also trigger when the user references FRCP 33(b)(3) verification, CCP 2015.5, 28 U.S.C. 1746, attorney vs. party verification, or asks for help checking whether discovery responses are properly executed. Even if the user just says "check these responses for defects" or "is this verification valid," use this skill.

Generates structured, citeable summaries of discovery documents (interrogatories, RFPs, RFAs, depositions, productions). Extracts admissions, inconsistencies, evidentiary gaps, and objections with precise source citations. Use when summarizing discovery responses, preparing for depositions, identifying discovery gaps, or building trial preparation materials.

Drafts Joint Discovery Plans and Proposed Scheduling Orders under FRCP 26(f) or state equivalents. Analyzes pleadings, court requirements, and case complexity to produce discovery timelines, ESI protocols, privilege procedures, and scheduling deadlines. Use when preparing Rule 26(f) reports, proposed scheduling orders, case management plans, or discovery frameworks after meet-and-confer.

Summarizes discovery documents (depositions, emails, contracts, interrogatories, medical/financial records) with Bates citations, impeachment flags, timeline extraction, and privilege alerts. Use when summarizing produced documents during discovery or pre-trial phases of U.S. commercial litigation.

Drafts discovery dispute resolution letters documenting meet-and-confer efforts and unresolved issues in U.S. litigation. Use when drafting meet-and-confer letters, discovery conference follow-ups, or pre-motion to compel correspondence during the discovery phase.

Builds and maintains a litigation-grade discovery deficiency and meet-and-confer tracker for compulsion motion practice. Use this skill when the user mentions deficient discovery responses, motion to compel preparation, meet-and-confer tracking, FRCP 37 sanctions, discovery dispute charts, joint discovery letters, informal discovery conferences, deficiency logging, or California Separate Statements. Also trigger when the user references boilerplate objections, privilege log deficiencies, incomplete productions, evasive answers, discovery conferral documentation, or asks for help organizing disputes for court. Even if the user just says "track these discovery problems" or "help me build a compel motion," use this skill.