Whistleblower Retaliation — Propounding Case Study
How a plaintiff's team built every discovery request from the legal elements of the case, not the narrative.
Outcome Snapshot
Full propounding workflow. 3 sets served. Every element covered.
A plaintiff's team serving written discovery in a whistleblower retaliation matter needed requests that would actually move the case rather than a set drafted from the narrative. Using Inquisita and the current CACI elements as a silent checklist, they built the plaintiff's Requests for Admission, Special Interrogatories, and Requests for Production, drove every request from an element of a claim or defense, and produced a strategy memo confirming nothing essential was left uncovered.
How it was done — 4-step workflow
Intake and ingest the pleadings
The team loaded the operative complaint and answer into Inquisita, then analyzed them to extract every cause of action, affirmative defense, and contested contention by pleading paragraph.
Both pleadings indexed and analyzedMap elements to CACI
Working backward from the current Judicial Council instructions, each element of every claim and defense was mapped to the proof that would establish or defeat it, and to the request type best suited to reach it.
Every element mapped — instructions kept internalDraft the plaintiff's three sets
Inquisita drafted all three sets in the firm's house format: RFAs locking facts the defendant cannot honestly deny, fact and contention SROGs (the FACTS/PERSONS/DOCUMENTS triplet tied to quoted pleading paragraphs), and RFPs framed with reasonable particularity.
62 requests · 5 contention tripletsAudit coverage with a strategy memo
An internal memo keyed every request to the element it serves, flagged any gap, confirmed the sets stayed within California's 35-request limits, and positioned the RFAs for a cost-of-proof motion if later denied.
0 elements uncovered · limits cleared