Legal Discovery Tracking

Depends on: FTR-36 — Excel Tracker (Base Capability)

What this is

Governs how discovery items (Interrogatories, Requests for Production, Requests for Admission) are tracked once they exist in some source form (served document, drafted set, markdown strategy file). This is specifically the tracking layer — one deterministic row per question, with status, response, and outcome fields the user can filter, sort, and check off. It is not the drafting layer and not the strategy layer; those stay in markdown, per the division of labor below.

The core division of labor: markdown (strategy documents) holds reasoning that changes and needs prose — why a cluster of questions exists, what evidence anchors it, what legal theory it supports. Excel (the tracker) holds the deterministic, versioned record of the questions themselves — exact numbering, exact text, status, outcome. The two are linked, not merged: every row has a Strategy Group field and a Strategy Doc Reference field naming the specific markdown file that explains that group's reasoning — the Excel tracker never duplicates strategy prose into a cell, it points to it.

Assess first

• Confirm FTR-36 (Excel Tracker Base Capability) is installed — this feature nests under it, not beside it, per FTR-36's own merge-behavior rule.
• Confirm the jurisdiction. This feature's schema, counting rules, and statutory citations are Georgia-specific (O.C.G.A. and Uniform Superior Court Rules) — a different jurisdiction's civil procedure code must be checked independently before assuming any of this transfers.

Ask, only if needed

• If the project's Document ID / file-naming convention for discovery rounds isn't already established: ask what round-naming pattern to use (e.g., DISC-01, Round-01) rather than inventing one.
• If it's not clear whether the project's discovery rounds predate cluster-based strategy organization: ask before leaving Strategy Group blank on existing rows — don't assume.

Write

Schema — one row per question

Building on FTR-36's general row-per-item model, columns for a legal discovery tracker:

Nomenclature — naming discovery rounds

A round's name must state which party propounded it, its sequence, and (for our outbound rounds) that it's ours. Our own outbound rounds: name plainly by sequence (Round-01, or a project's own short code like DISC-01). The other party's inbound rounds: explicit INBOUND marker plus sequence (<code>-INBOUND-01). Track the other party's round count independently — their round 1 and our round 1 are unrelated sequences that happen to share a number. Never name a round or folder using only physical mail direction.

Folder structure — one folder per party, containing that party's questions AND the answers to them

The organizing principle is whose questions are these, not which direction did this arrive from. An answer to OUR questions belongs in OUR folder even though it physically arrived from the other party, since it's the answer half of our own round.

Structure:

Discovery Root\
|-- Our Party\
|   |-- Round-01\
|   |   |-- final\     - finalized version served (or draft\ if not yet served)
|   |   |-- filed\      - actual served\court copy plus certificate of service
|   |   |-- responses\  - OTHER party's answers to OUR round-01 (belongs here, not their folder)
|   |-- strategy\       - research\strategy shaping OUR questions and analyzing THEIR answers
|   |-- Party_Discovery_Tracker.md
|-- Other Party\
|   |-- Round-INBOUND-01\
|   |   |-- requests\   - documents THEY served on us
|   |   |-- responses\  - OUR answers to THEIR questions (belongs here, not our folder)
|   |-- strategy\       - research shaping OUR answers to THEIR questions
|-- strategy\           - ONLY genuinely direction-neutral research; most belongs in a party folder

Test to apply: ask whose question does this answer or analyze, not whose name is on the email. The Excel tracker for a party's own discovery lives in that party's folder, same level as (not nested inside) round subfolders, alongside the markdown narrative tracker. The _backup folder (per FTR-36) sits beside the Excel tracker at that level.

Strategy folder taxonomy — seven categories

The organizing test: does this document generate or support the strategy, or is it the strategy itself? Exactly one document per party is the strategy itself (Master Strategy). Everything else is research that feeds it. All seven categories live flat in strategy — no subfolder split, since the naming convention already encodes the category in the filename prefix.

Naming pattern: <ProjectCode>-<CategoryCode><NN>_<Descriptive_Title>[_<Qualifier>].<ext>. MS carries no sequence number (exactly one per party, edited in place). Every other category uses a two-digit sequence assigned in creation order within its category, per party. No embedded dates — the filesystem timestamp and _backup history already carry that. QR items carry one additional requirement: the filename or a header field must name the specific question(s) the research is tied to, not just a topic (e.g. ..._re_RFA-52.md, not a bare topic title).

On installation, write a README.md to each party's strategy folder explaining this taxonomy, naming pattern, and the counting rules below, so they're looked up rather than re-derived each session. This README is written once and is not duplicated into Agent Instructions beyond an enforcement rule and a pointer to it.

Discovery counting rules

Only Interrogatories have a cap and need real subpart counting. These specific numbers and citations are Georgia's rules — a different jurisdiction must be checked independently before assuming any of this transfers.

Strategy document backup

The Master Strategy document is backed up before every edit, using the identical mechanism FTR-36 specifies for the Excel tracker — PowerShell Copy-Item to a strategy\_backup folder, timestamped, verified non-zero, bundled into the same script as the edit. Applies specifically to the one Master Strategy document per party, not every file in strategy — research documents are typically static once written.

Accompanying reference package — Georgia_Discovery_Process_-_Statutes_and_Guide.zip

This feature ships with a downloadable reference package, separate from this spec document: a general-purpose (non-case-specific), Georgia-jurisdiction bundle of the governing statutes and a practical counting/objection guide. On installation, this package should be:

1. Downloaded from the feature site alongside this spec.
2. Unzipped into the host project's research/reference location as its own top-level folder, Georgia_Discovery_Process_-_Statutes_and_Guide\ — not merged file-by-file into an existing structure.
3. Referenced from the project's Agent Instructions or CLAUDE.md as a pointer only (path plus one-line purpose) — never re-summarized or duplicated into the instructions themselves.

Contents: 01_Statutes\ (20 verbatim Georgia and federal statutes covering discovery mechanics, evidence/privacy law, and privilege/confidentiality); 02_Guides\ (a three-part practice guide covering discovery tools and cap-counting, objection/verification/waiver, and the escalation pipeline); README.md (top-level index). Jurisdiction scope is Georgia only, stated explicitly throughout the package. Download: data/items/georgia-discovery-process-statutes-and-guide.zip

What this doesn't cover

• The base Excel access method, backup mechanics, and verification discipline — see FTR-36.
• The project-cache sidecar mechanism for a legal discovery tracker — FTR-36's sidecar section applies as-is, without legal-specific variation.
• Court-formatting or filing conventions for the underlying discovery documents (captions, certificates of service, verification blocks) — remains governed by whatever brand/formatting spec and legal research the host project already maintains.
• Automated parsing of a new discovery document straight into tracker rows — a reasonable future extension, not yet specified.

Confirm

Confirm: Legal Discovery Tracking is installed, nested under FTR-36's EXCEL TRACKER section — schema, nomenclature, folder structure, and strategy taxonomy are in place, and the Georgia_Discovery_Process_-_Statutes_and_Guide reference package is unzipped into the project's research location and pointed to from Agent Instructions. Want to install another, or is that everything for now?