Plaintiff’s Issues and Material Facts

Structured workflow for plaintiff’s issues and material facts: organise the supplied facts and documents, identify missing information, draft or analyse in stages, and verify facts, authorities and assumptions before use.

This is a reusable litigation prompt from the Litigation AI Prompt Repository. It is intended for Malaysian civil litigation but can be adapted by changing the placeholders. Use the Universal Litigator Control Block first where source discipline, adversarial review and authority verification matter.

Prompt

Acting for the proposed Plaintiff, analyse `[MATERIALS]` and formulate:

1. the causes of action reasonably available;
2. the material facts necessary for each cause of action;
3. facts relevant only as evidence, which should ordinarily not be pleaded;
4. legal issues likely to arise;
5. conditions precedent and procedural prerequisites;
6. relief flowing from each claim;
7. alternative or inconsistent cases requiring express pleading;
8. allegations requiring particulars;
9. facts or allegations that should not presently be pleaded because support is inadequate;
10. anticipated defences and material facts needed to meet them.

Produce: (a) an issues list; (b) a material-facts matrix; (c) a proposed pleading architecture with numbered headings; and (d) a list of further instructions required before drafting.