executing-plans
executing-plans
Use when executing an implementation plan in the current session as the implementer yourself — your human partner chose inline execution, or no subagent tool is available
interrogatories-to-defendantDrafts plaintiff's interrogatories to defendant in personal injury litigation with caption, definitions, instructions, and substantive questions. Triggers when user needs to draft interrogatories, written discovery requests to a defendant, or PI discovery sets. Enforces numerical limits, subpart counting, and contention interrogatory practices.
Independent GitHub snapshot · Automated classification · Original documentation governs
name: interrogatories-to-defendant language: en description: Drafts plaintiff's interrogatories to defendant in personal injury litigation with caption, definitions, instructions, and substantive questions. Triggers when user needs to draft interrogatories, written discovery requests to a defendant, or PI discovery sets. Enforces numerical limits, subpart counting, and contention interrogatory practices. tags:
Drafts interrogatories that pin down defendant's factual contentions, identify witnesses and evidence, and build the foundation for depositions and trial.
Standard litigation caption. Title: "Plaintiff's [First/Second/etc.] Set of Interrogatories to Defendant."
Define at minimum:
| Term | Scope |
|---|---|
| IDENTIFY (person) | Name, address, phone, employer, relationship to parties |
| IDENTIFY (document) | Author, date, type, custodian, location, Bates number |
| IDENTIFY (communication) | Date, participants, medium, substance |
| PERSON | Natural persons and all entities |
| DOCUMENT | All tangible and ESI formats |
| COMMUNICATION | Every form of information exchange |
| INCIDENT | Specific event(s) giving rise to the lawsuit |
| YOU/YOUR | Defendant including agents, employees, representatives |
Draft broadly to prevent evasion; keep defensible.
Tailor to the specific facts, claims, and defenses. Organize by category:
A. Witness Identification
B. Defendant's Version of Events
C. Evidence Identification
D. Personal Injury–Specific
E. Contention Interrogatories For each affirmative defense: state every supporting fact, identify every supporting document, identify every knowledgeable person.