# Analyze Counterparty Requests For Production For Objectionable And Overbroad Discovery Demands > Reviewing incoming requests for production requires evaluating each request against scope-of-discovery principles, applicable case-specific orders, and governing agreements to identify requests that are objectionable as overbroad, unduly burdensome, privileged, or beyond permissible scope. - Skill: `finchipaiorg/analyze-counterparty-requests-for-production-for-objectionab` (Agent Skill) - Install (CLI): `npx skillmds@latest add finchipaiorg/analyze-counterparty-requests-for-production-for-objectionab` - Raw SKILL.md: https://api.skillmd.com/api/skills/finchipaiorg/analyze-counterparty-requests-for-production-for-objectionab/raw - Safety review: pending - Works with: Claude Code, Claude.ai, OpenAI Codex - Category: Product & Planning - Author: FinchipAIOrg (https://skillmd.com/u/finchipaiorg) - Updated: 2026-09-22 - Page: https://skillmd.com/skills/finchipaiorg/analyze-counterparty-requests-for-production-for-objectionab --- # Skill: Analyze Counterparty Requests for Production for Objectionable and Overbroad Discovery Demands — Issue Identification Memorandum ## 1. Subject-matter triage - Start by identifying the governing litigation posture, the operative case orders, the discovery deadline, and any confidentiality or privilege-protection regime before assessing the requests. - Read the deal documents, any schedule or order that fixes the dispute scope, and the strategy email together so that objections track the real business and litigation boundaries. - Treat each request as a separate item unless the source materials clearly make the same objection turn on the same limitation across a defined group of requests. ## 2. Failure modes the skill is correcting - Calling a request overbroad without naming the limiting principle that controls it, such as relevance, proportionality, temporal scope, subject-matter scope, undue burden, privilege, or duplicative burden. - Missing case-management, protective, or clawback provisions that narrow or shape production obligations. - Collapsing complete objections, partial objections, and no-objection requests into one undifferentiated response posture. - Failing to connect each objection to a concrete response recommendation the client can use in drafting. - Omitting the interaction between discovery scope and preservation, collection, format, or confidentiality obligations. ## 3. Legal frameworks / domain conventions that apply - Apply the governing civil discovery rules on relevance, proportionality, specificity, and permissible objections, including the rule requiring objections to be stated with particularity. - Apply the response deadline set by the applicable discovery rules, stipulation, or case order. - Apply any protective order, ESI protocol, clawback procedure, or privilege-log requirement that affects production. - Use common objection categories where supported by the record: overbroad time period, undefined or vague terms, cumulative or duplicative requests, undue burden, disproportionate scope, privileged material, work product, and material outside the permitted discovery universe. - When an objection is partial, identify the non-objectionable portion and preserve a commitment to produce responsive, non-withheld material. - Do not state an objection as a conclusion alone; tie it to the governing rule, order, or agreement that makes the objection available. ## 4. Analytical scaffolds - Enumerate the requests first in request-number order, and identify any request groups that rise or fall together because they share the same operative defect. - For each request, extract the controlling terms, the documents or orders that constrain the request, and the practical burden or privilege issue created by the demand. - Test each request against the source set in this order: governing agreement, case order, strategy materials, then the request text itself. - For each identified issue, state: - the severity on a uniform ordinal scale defined at the top of the memo; - the specific limiting principle or rule; - the source document or order that interacts with the request; - the practical consequence for the client if the request is not narrowed or resisted. - Distinguish between a request that should be rejected outright and one that should be narrowed with an express willingness to produce responsive, non-objectionable documents. - Where privilege or work-product concerns exist, flag the need to withhold and log as appropriate, and note any clawback protection that softens the risk. - Where the request implicates ESI collection, format, or custodial scope, identify the operational burden and any mismatch with the agreed production protocol. - If the record shows a single relevant timeframe, scope, or category set, say so expressly and explain why no broader comparison is needed. ## 5. Vertical / structural / temporal relationships - Track how each request interacts with the deal documents, the case order, and the strategy email; a request may be facially ordinary but objectionable when measured against those constraints. - Track temporal limits carefully: if the source set narrows the relevant period, requests seeking documents outside that window should be flagged as overbroad or disproportionate. - Track subject-matter nesting: requests tied to one transaction issue, party, or document category should not be expanded into a general company-wide search absent support in the source set. - Track downstream effects: an objection may affect collection scope, privilege review, custodial burdens, confidentiality designations, or the timing of the response. ## 6. Output structure conventions - Use a concise internal memo format with a short executive summary, a request-by-request issue list, and a closing recommendations section. - Define the severity scale once near the top and apply it uniformly to every request entry. - For each request entry, include: - Request number - Severity - Objection basis - Source support from the deal documents, case order, or strategy materials - Recommended response language - Whether documents are to be withheld, produced in part, or produced without objection - Prioritize problematic requests first, then requests suitable for partial objections, then requests with no material objection. - End with an explicit Recommended Actions section that assigns the next step to the relevant role and ties it to the response deadline or the nearest litigation milestone. - Match the required file name exactly: `rfp-issue-memorandum.docx`.