Complaint Drafter
When you have the client's story and the core documents in hand and want a structured first draft of a complaint that shows exactly which facts support each element before you start writing.
A complaint sets the boundaries of the whole case. Every factual allegation you plead becomes something you may have to prove, and every element you miss becomes an opening for a motion to dismiss. The hard part of a first draft is not the prose; it is making sure each element of each claim rests on a specific fact you can actually support, and that nothing in the client's own documents undercuts the story.
This prompt keeps Claude tied to the record. You tell it you represent the plaintiff, name the court, and paste the client facts and key documents in tagged blocks. Claude drafts numbered allegations with a source note after each one, leaves every element as a bracketed placeholder for you to confirm, and then produces a review table that rates support for each element as strong, thin or missing. It also lists pleading-standard risks and pre-suit issues it spots in the documents, such as notice-and-cure clauses or arbitration provisions.
The draft is a starting point, not a filing. Claude is told not to cite cases or statutes, so the legal standard for each claim, the jurisdictional basis, and any limitations analysis are yours to supply and verify. You are also responsible for the factual basis of every allegation you sign. Review the draft against the source documents and your jurisdiction's rules before it goes anywhere near the court.
The Prompt
I represent the plaintiff, [CLIENT NAME], in a dispute with [DEFENDANT NAME(S)]. We plan to file in [COURT AND JURISDICTION]. I need a first draft of the complaint for my review. <client_facts> [PASTE CLIENT INTAKE NOTES, TIMELINE OR FACT SUMMARY] </client_facts> <document name="[DOCUMENT 1 NAME, e.g., Supply Agreement dated ...]"> [PASTE DOCUMENT TEXT] </document> <document name="[DOCUMENT 2 NAME]"> [PASTE DOCUMENT TEXT] </document> Claims I am considering: [e.g., breach of contract, unjust enrichment] Relief sought: [DAMAGES, INJUNCTION, DECLARATORY RELIEF, FEES IF AUTHORIZED] Draft the complaint using only the facts in the materials above: 1. Caption with [COURT], [PARTIES] and [CASE NO.] placeholders. 2. Parties, jurisdiction and venue, with the basis for each left as [JURISDICTIONAL BASIS] and [VENUE BASIS] for me to confirm. 3. Numbered factual allegations, one fact per paragraph. After each, add a source note such as [Source: Supply Agreement §4.2: "quoted language"]. If a fact comes only from the client notes, mark it [Source: client account, needs corroboration]. 4. One count per claim. State each element as [ELEMENT: description] for me to confirm under [APPLICABLE LAW] and list the paragraphs that support it. Do not cite cases or statutes. 5. Prayer for relief, a [JURY DEMAND] placeholder, a signature block, and a [VERIFICATION, IF REQUIRED] placeholder. After the draft, give me a review table: Count | Element | Supporting paragraphs | Support (strong, thin, missing) | What would fix it. Then list pleading-standard risks: conclusory allegations, facts pled on information and belief, anything that may require heightened particularity (such as fraud), and pre-suit issues visible in the documents (notice, cure, arbitration, forum selection, limitations). Flag uncertainty instead of filling gaps. This is a draft for attorney review. I will confirm every element and verify any authority before filing.
Example Output
A captioned draft complaint with numbered, source-tagged allegations, counts with bracketed elements, a prayer for relief, and a review table rating support for each element.
Illustrative example — names, figures, and facts are fictional.
DRAFT COMPLAINT (FOR ATTORNEY REVIEW) [COURT] Harborline Fixtures, LLC, Plaintiff, v. Granite Peak Supply Co., Defendant. [CASE NO.] FACTUAL ALLEGATIONS (EXCERPT) 12. On March 3, 2025, Plaintiff and Defendant executed a Supply Agreement for 4,000 custom display units. [Source: Supply Agreement, preamble and §1.1: "Supplier shall deliver 4,000 Units per Schedule A."] 13. The Agreement required delivery of all units by June 30, 2025. [Source: Schedule A: "Final delivery date: June 30, 2025."] 14. Defendant delivered 1,150 units by June 30, 2025. [Source: client account, needs corroboration (no delivery receipts provided)] 15. On July 8, 2025, Plaintiff sent written notice of breach. [Source: Letter from M. Okafor dated July 8, 2025: "This letter serves as written notice of breach under Section 14.2."] COUNT I: BREACH OF CONTRACT [ELEMENT: existence of a valid contract] ¶¶ 12-13 [ELEMENT: plaintiff's performance or excuse] ¶ 11 [ELEMENT: defendant's breach] ¶ 14 [ELEMENT: damages] ¶¶ 16-18 REVIEW TABLE Count I | Contract | ¶¶ 12-13 | Strong | None Count I | Plaintiff's performance | ¶ 11 | Thin | Add payment records for the deposit Count I | Breach | ¶ 14 | Thin | Obtain delivery receipts or bills of lading Count I | Damages | ¶¶ 16-18 | Thin | Cover-purchase invoices not provided PLEADING AND PRE-SUIT RISKS - §14.2 of the Agreement requires 30 days' written notice and opportunity to cure. The July 8 letter is in the file; confirm the cure period ran before filing. - §17 contains a forum-selection clause naming [COUNTY]. Confirm the chosen court complies. - ¶ 17 alleges lost customers "upon information and belief"; consider removing it or adding specifics. All names and facts are fictional and illustrative.
Tips
- •Paste the contract or other key documents in full, not summaries; the source notes are only as good as the text Claude can quote.
- •Treat every [ELEMENT] placeholder as a to-do: confirm the elements from your jurisdiction's pattern instructions or controlling authority before filing.
- •Any allegation tagged 'client account, needs corroboration' is a cue to find a document or witness before you sign under your pleading obligations.
- •Run the finished draft through motion-to-dismiss-drafter from the defense side to see how the other side will attack it.
- •The output is a draft for attorney review; verify any rule or authority you add, since Claude was told not to supply citations.
Frequently Asked Questions
Will Claude tell me the elements of each claim?
Not in this prompt, by design. The elements are left as bracketed placeholders because they vary by jurisdiction and claim, and an invented or slightly wrong element list is worse than a blank. Fill them in from your jurisdiction's pattern jury instructions or controlling authority, then ask Claude to re-check which paragraphs support each confirmed element.
How does this help with plausibility challenges?
The review table rates each element as strong, thin or missing based on the specific facts pled, and the risk list calls out conclusory allegations and anything pled on information and belief. That shows you where a motion to dismiss would aim before the defense finds it, so you can add facts, gather documents, or drop a weak count before filing.
Can I use this for claims that require particularity, like fraud?
Yes, but expect more flags. The prompt asks Claude to identify allegations that may require heightened particularity, and it will usually point out missing who, what, when, where and how details. Use those flags as an interview checklist with the client, and confirm the applicable particularity standard in your court before relying on the draft.
Should I paste privileged client notes into Claude?
Only in a setup your firm or legal team has approved for confidential client material, with appropriate data-handling terms. Your duties of confidentiality and competence apply to the tool you choose. Many lawyers strip unnecessary personal identifiers before pasting and keep the full record in their own file system.
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