← All workflows

Discovery Plan

Draft Discovery Plans & Scheduling Orders in Minutes

12 minutes with Para

Explore this workflow

Get started with Para

Para is an AI colleague for legal teams. Send it this work by email, Teams or Slack, and it hands back the finished document.

12 minutes with Para

What you'll need

  • Complaint, Answer & Pleadings
  • Court Information & Local Rules
  • Meet-and-Confer Notes

Plans from $20 a month, with usage included.

Workflow

Overview

CaseMark's Discovery Plan skill transforms pleadings, court requirements, and meet-and-confer details into comprehensive Joint Discovery Plans and Proposed Scheduling Orders. It automates the labor-intensive process of mapping claims to discovery needs, drafting ESI protocols, establishing privilege procedures, and building milestone-driven scheduling orders that comply with FRCP 26(f) or state equivalents.

Drafting Joint Discovery Plans and Proposed Scheduling Orders is one of the most time-consuming tasks in early litigation. Attorneys must manually cross-reference pleadings, local rules, standing orders, and meet-and-confer agreements while ensuring every claim maps to appropriate discovery, ESI protocols are comprehensive, and deadlines are realistic—all under tight court-imposed timelines.

CaseMark automates the entire discovery planning workflow by analyzing your pleadings, court requirements, and meet-and-confer details to produce a complete, court-ready Joint Discovery Plan. The AI maps each claim and defense to specific discovery needs, generates tailored ESI protocols and privilege procedures, and builds a milestone scheduling order—giving attorneys a polished draft in minutes instead of hours.

How to hand this to Para

  1. 1. Send Para the files

    Email them, drop them in a Teams or Slack message, or upload them.

  2. 2. Para runs the Discovery Plan skill

    It works from your files and checks its citations against the record.

  3. 3. The finished document comes back

    Para returns it where you asked, usually as a DOCX, and offers the next step.

Example request · email, Teams or Slack
Para, run the Discovery Plan skill for the Garcia matter. I've attached the Complaint, Answer & Pleadings, Court Information & Local Rules and Meet-and-Confer Notes. Send the finished draft back here as a DOCX.

What Para does

  1. 1. Upload your pleadings, court information, and meet-and-confer notes
  2. 2. AI analyzes claims, defenses, and case complexity to determine discovery scope
  3. 3. Review the generated Joint Discovery Plan with ESI protocols, timelines, and scheduling deadlines
  4. 4. Export your court-ready document in your preferred format (DOCX, PDF)

What you get

  • Caption & Introduction

  • Discovery Subjects & Scope

  • ESI Protocol

  • Privilege Procedures

  • Discovery Limitations

  • Phased Discovery Plan

  • Proposed Scheduling Order with Milestone Deadlines

  • Signature Blocks & Certificate of Service

What it handles

  • Claim-by-claim discovery scope analysis tied to legal elements

  • Comprehensive ESI protocol with format, metadata, and TAR provisions

  • Automated milestone deadline scheduling in tabular format

  • FRE 502(d) clawback and privilege log procedure drafting

  • Proportionality analysis under Rule 26(b)(1)

  • Phased discovery recommendations for complex cases

Required documents

  • Complaint, Answer & Pleadings

    All complaints, answers, amended pleadings, counterclaims, and cross-claims in the case

    .pdf, .docx

  • Court Information & Local Rules

    Court/division details, judge's standing orders, local rules, and any model templates provided by the court

    .pdf, .docx

  • Meet-and-Confer Notes

    Notes from the Rule 26(f) meet-and-confer conference including date, participating attorneys, and agreements reached

    .pdf, .docx, .txt

Supporting documents

  • Initial Disclosures

    Initial disclosures if already exchanged between parties

    .pdf, .docx

  • Existing Court Orders

    Any existing case management conference minutes, scheduling preferences, or prior court orders

    .pdf, .docx

  • Prior Discovery Plans

    Discovery plans from related cases or prior iterations for reference

    .pdf, .docx

Why teams use it

Reduce hours of manual drafting to minutes with AI-generated, court-ready discovery plans that cover every required section

Ensure nothing falls through the cracks with systematic claim-by-claim discovery scope analysis tied to legal elements and factual disputes

Produce sophisticated ESI protocols and privilege procedures that reflect current best practices and protect client interests

Generate proportionality-informed discovery limitations and phased discovery recommendations tailored to your case's complexity

Questions

Does this tool comply with FRCP 26(f) requirements?

Yes. CaseMark's Discovery Plan skill is specifically designed to produce Joint Discovery Plans and Proposed Scheduling Orders that satisfy FRCP 26(f) requirements. It also adapts to state equivalents when applicable.

Can it handle complex multi-party or multi-defendant cases?

Absolutely. CaseMark analyzes case complexity and automatically recommends phased discovery, multi-defendant sequencing, and liability/damages bifurcation when warranted. The tool scales to match the sophistication of your case.

Does the ESI protocol cover modern e-discovery standards?

Yes. CaseMark generates comprehensive ESI protocols covering production formats (native, TIFF, searchable PDF), metadata fields, search term methodology, TAR/predictive coding provisions, and preservation obligations aligned with current best practices.

Will the output conform to my court's local rules and standing orders?

CaseMark incorporates the court information, local rules, and standing orders you provide to tailor the discovery plan and scheduling order to your specific judge and jurisdiction's requirements.

How does CaseMark determine appropriate discovery limitations?

CaseMark performs a proportionality analysis under Rule 26(b)(1), weighing the importance of issues, amount in controversy, relative access to information, and party resources. It then proposes reasonable limits on depositions, interrogatories, RFAs, and other discovery tools.

Can I customize the generated plan before filing?

Of course. CaseMark produces a fully editable document that you can review, modify, and refine before filing. The AI-generated draft gives you a comprehensive starting point that captures all required elements.

Related