Defendant’s Issues and Material Facts

Structured workflow for defendant’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 Defendant, analyse the Statement of Claim, client instructions and `[MATERIALS]`.

For every substantive allegation:

- identify what is admitted, denied, not admitted or outside the Defendant’s knowledge;
- state the factual basis and source for the proposed response;
- identify any positive case that must be pleaded;
- identify facts supporting limitation, jurisdiction, standing, estoppel, waiver, illegality, set-off, causation, mitigation or other defence;
- identify allegations requiring a specific traverse or particulars;
- identify possible counterclaims, contribution or third-party proceedings;
- flag inconsistent client instructions or answers unsupported by documents.

Produce an allegation-response matrix, a defence theory, proposed issues, a material-facts matrix and targeted follow-up questions. Do not draft evasive bare denials.