Discovery Gaps
What are we missing?
4
Propositions with no supporting document
4
Referenced documents not located
2
Identities unresolved
3
People with incomplete contact details
- CriticalOpenMissing referenced document
Security alert record for the September 2 export
Count 2 — Misappropriation of Trade Secrets
Complaint ¶ 26 says the alert was suppressed from the same session. The log shows a different account. The underlying alert record has not been collected and may have rolled off.
Next step: Ask Ruiz and Meridian's security vendor for any backup of the alert history.
Assigned to Mei Tanaka
- HighIn progressUnauthenticated evidence
Bank records have no business-records certification
Count 6 — Unjust Enrichment
Front Range Commerce Bank's return did not include the FRE 902(11) certification its cover letter promised.
Next step: Call the bank's legal process unit; if nothing in 10 days, serve a deposition subpoena on the custodian.
Assigned to Carla Mendes
- HighOpenContradictionAI found
¶ 26 may overstate who suppressed the alert
Count 2 — Misappropriation of Trade Secrets
The access log attributes the suppression to 'security-alerts', not Halvorsen's account.
Next step: Confirm with Ruiz before relying on ¶ 26; consider amending.
Assigned to Jonah Pierce
- HighOpenIdentity unresolved
Identify 'J.M.' in Rennick's Slack
Count 2 — Misappropriation of Trade Secrets
The contractor who wrote about porting the seasonality layer is known only by initials.
Next step: Interrogatory No. 9 to Rennick; check Desai's texts for a first name.
Assigned to Carla Mendes
Run the discovery agent
Compare what the pleading alleges against what the evidence, witnesses and damages records contain. For each gap, state what is absent, what it touches, and the concrete next step.
Find unsupported propositions
Identify propositions and allegations with no supporting document and no identified witness, ranked by how central each is to an element.
Find contradictions
Identify places where two sources cannot both be accurate. Cite both sides and say what would resolve the tension.
What Are We Missing?Each Gap, With the Step That Closes It.
Every gap says what is absent, which count or element it bears on, the next step, and who owns it, ranked by severity. It stays open until someone closes it with what was found.
Nothing describes missing evidence as if it existed.
- HighOpenUnauthenticated evidence
Bank records have no business-records certification
Count 6 — Unjust Enrichment
Front Range Commerce Bank's return did not include the FRE 902(11) certification its cover letter promised.
Next step: Call the bank's legal process unit; if nothing in 10 days, serve a deposition subpoena on the custodian.
Assigned to Carla Mendes
- Resolved by Carla Mendes · FRE 902(11) certification received and filed as MERIDIAN-000043.
Sorted by What’s Missing.Documents, Identities, Witnesses, Figures.
Gaps are grouped by kind: referenced documents not located, evidence not yet authenticated, identities unresolved, contact details incomplete, allegations with nothing behind them, damages with no computation. Filter to one kind and work it through.
- HighOpenIdentity unresolved
Identify 'J.M.' in Rennick's Slack
Count 2 — Misappropriation of Trade Secrets
The contractor who wrote about porting the seasonality layer is known only by initials.
Next step: Interrogatory No. 9 to Rennick; check Desai's texts for a first name.
Assigned to Carla Mendes
- LowOpenIdentity unresolved
Identify 'A.P.' copied on the Northstar proposal
Count 5 — Tortious Interference with Business Relationships
Could be a Northstar employee or a Rennick salesperson.
Next step: Ask Castellano.
From Gap to Request.Discovery Requests, Drafted From the Gaps.
Tick the gaps and choose requests for production, interrogatories or requests for admission. The draft opens in Composer, ready for counsel to edit.
Draft discovery requests from these gaps
- Identify 'J.M.' in Rennick's Slack
- Rennick's bank records
- Calloway's invoices from Halvorsen
Three Agents, One Question.The Pleading Against the Record.
One compares what the pleading alleges against the evidence, witnesses and damages. One finds propositions with nothing behind them. One finds contradictions. Each proposes; a person decides what enters the record.
Run the discovery agent
Compare what the pleading alleges against what the evidence, witnesses and damages records contain. For each gap, state what is absent, what it touches, and the concrete next step.
- MediumOpenUnsupported allegationAI found
No evidence yet of intent to induce reliance (Count 4)
Count 4 — Fraudulent Misrepresentation
Element 3 of Count 4 has no linked fact or document.
Next step: Look for internal Halvorsen emails about the reports.