Ask for every element. Answer from the record. Compel what is still missing.
Written discovery in three stages on one matter record: the first sets drafted from the complaint, objections and answers drafted from the documents you are producing, and a discovery gap analysis of what came back that ends in a meet and confer letter and a Motion to Compel, with the correct law cited.
In Early access with a first group of firms. Not generally available.
Three stages, one matter record.
A defense firm uses all three: it answers the plaintiff’s discovery, propounds its own, and enforces it.
- 1Propound
Ask what the elements require
Read the complaint. Draft interrogatories, requests for admission and requests for production tied to the elements of every cause of action.
Stage 1 → - 2Respond
Answer from what you are producing
When discovery is served on your client: named objections and answers grounded in the producible documents, in your firm’s voice.
Stage 2 → - 3Enforce
Turn evasion into a record
Every response tracked across rounds to a cure status, then to the letter, the motion, the second set and the deposition.
Stage 3 →
The first sets, drafted from the complaint.
Upload the complaint and get a first draft of your opening written discovery.
The system reads the pleading, lists each cause of action as pleaded, and pulls the factual allegations with their paragraph numbers. For each cause of action it looks up the elements in a reference library built from pattern jury instructions, rather than asking a model to recall them. Where it finds no match, it says so.
Then it drafts three sets grounded in those elements and the pleaded facts, and a second pass reads every request the way opposing counsel will.
Three sets, one foundation
- Special interrogatories organized by topic, with lettered subparts.
- Requests for admission held to one fact each, so the answer is admit or deny.
- Requests for production framed as defined, time-bound categories.
- A second pass reviews every request for vagueness, overbreadth, compound phrasing and work-product traps, and rewrites the weak ones.
- Interrogatories are held to the numeric limit your forum sets.
- You review the three sets on one screen and edit, add or delete before anything goes out.
Objections you would defend on a motion to compel. Answers from the record.
When interrogatories, requests for admission or requests for production are served on your client, this stage drafts the responses.
Bring the documents you are producing in from Google Drive, Dropbox or NetDocuments Early access instead of re-uploading them. You mark each document producible, privileged, work product, confidential or strategy only. Only producible documents can supply facts. You choose your firm’s written playbook, which sets how candid or how guarded the responses should be.
The playbook governs voice. The objection bank governs objection names. The documents govern facts. Those wires do not cross.
Objections by name, answers by page
- For each request, the relevant passages are found in the producible documents.
- Objections are selected by name from a fixed objection bank, not improvised.
- Interrogatories get a narrative or a business-records reference. Admissions get admit, deny, partial or lack of knowledge. Production requests get will produce, will not produce or no responsive documents.
- Every factual statement is tied to a document and a page range.
- A second pass checks each draft against the playbook. A set-level review looks for contradictions, unanswered requests and privilege slips.
- The attorney reviews and edits every response. Nothing is served by the system.
A production nobody has sorted? Start with isResponsive().
On the defense side you usually hold the documents: tens of thousands of them, unsorted, responsive and not, not yet produced, and a review budget that does not cover them.
isResponsive() is our open-source eDiscovery responsiveness review engine. It runs on hardware you control and makes zero calls to any AI vendor’s API. It screens privilege first, scores every document against each request for production with a quoted citation span, and ends in a counsel-signed Defensibility Certificate. About $70 of compute per 100,000 documents.
The responsive set it certifies is the set Stage 2 answers from, and the set whose gaps Stage 3 measures. It is free, and it is the front door to everything on this page. The methodology is published today; the source publishes at first release, and until then we run it with you in a demo.
From the pile to the motion
- The pile
Unsorted documents, responsive and not, on your own hardware. Nothing leaves your walls.
- isResponsive()
Per-request determinations with quoted spans, privilege screened first, a signed certificate at the end.
- The responsive set
Flows into the matter. Answers are grounded in it; production gaps are measured against it.
- Discovery Framework
The responses, the meet and confer letter and the Motion to Compel draw on the same set.
Gap analysis first. Then the papers that enforce it.
Drop in every response at once: initial, supplemental and amended, plus the complaint. All together. The system sorts them.
It splits the responses into one unit per request, chains each unit’s versions across rounds, and assigns a cure status. It classifies how each answer falls short, finds the patterns that run across responses, and drafts a deficiency paragraph for each unit. That is the discovery gap analysis. Then you decide what to fight and what to drop.
How an answer falls short
- Scope narrowing: the response redefines the question and answers the narrower one.
- Boilerplate objections kept after supplementation.
- A document dump by page range, with nothing identified.
- A truncated response, which is no response at all.
- A privilege objection with no log behind it.
- A contradiction between two responses, or between a response and the complaint.
- An affirmative defense with no facts behind it.
Cure status, request by request
The supplemental response answers the request. The letter says so.
Some subparts answered. Objections or gaps remain.
Feeds the letter, the separate statement, the second set and the outlines.
No supplemental response was served.
- In the letter
A sentence in the deficiency paragraph
Every claim carries a citation you can click.
- In the fact table
A row that classifies the answer
What was extracted, how complete it is, how it evades, what it is worth.
- In the response
The sentence opposing counsel wrote
Highlighted in the operative version, with the earlier round one click away.
Every claim in the deficiency paragraph traces to a row in the fact table, which traces to a sentence in the response. Follow the chain before you sign the letter.
One analysis. Five work products.
Multi-round framing: it credits what was cured and keeps fighting what was not. Each section quotes the response, says why it fails, cites the governing section, states what must be provided and ties relevance to the complaint’s own paragraphs.
From: still evasive, partially curedThe separate statement in the format the court’s rules require: the text of the request, the text of the response, the statement of insufficiency and the reasons a further response is justified.
From: still evasive after the letterDrafted from the admissions and the gaps the first set exposed. Each proposed interrogatory names the response or the pattern it came from.
From: partially cured, scope narrowing, patterns across responsesOutlines by witness, prioritized by how often the witness surfaces across the response set, with topics tied to the responses behind them.
From: still evasive, patterns across responsesWhere one response contradicts another, or contradicts the complaint’s own allegations, the conflict is flagged where it occurs and carried into the outline.
From: contradictions between responsesWith the correct law cited
The letter and the motion cite statutes, rules and cases. None of those citations is written by a model. They enter the draft the way every citation enters LitigationOS: from the verified record, with statute citations linked to the official text and case authority checked for subsequent history before it can reach the page.
How Solon verifies the law →Held to the court’s own rules
Local Rules hold the motion’s formatting to the rules of the court you are filing in, and compute deadlines the way that court computes them. MotionLogic identifies the procedurally correct motion and flags a filing that would waive rights.
Local Rules →You sign the letter. You make every call in it.
Decide what to fight, what to drop
Include, exclude or mark for revision, one request at a time. The decisions stay in sync across triage, review and the letter, and the items that still need your eyes are counted for you.
Edit in place
Prune the meet and confer letter where it sits. An edit to a deficiency paragraph carries back to the review screen, so the letter and the analysis never disagree.
Nothing is served. Nothing files itself.
Every set, every response, every letter and every motion stops for attorney review. The attorney is the decision-maker of record, by design.
What litigators ask.
Which side is it for?
Both. Stage 1 and Stage 3 serve the propounding party. Stage 2 serves the responding party. A defense firm uses all three: it answers the plaintiff’s discovery, propounds its own, and enforces it.
Does it replace document review?
No. isResponsive() does the responsiveness review, on your own hardware. Discovery Framework works from the responsive set that review certifies.
Who writes the citations in the letter and the motion?
Nobody writes them. They are retrieved from the verified record. No model in the system is allowed to write a citation.
Does it serve or file anything?
No. Nothing files itself. Every work product stops for attorney review.
Is it available now?
Discovery Framework and the Motion to Compel are in Early access: running with a small, named first group of firms, not generally available. Status badges are the source of truth.
Decide what to fight. Decide what to drop.
In a demo we walk a set of responses through triage on an illustrative matter: cure status, the deficiency paragraphs, the letter and the separate statement.