Draft a Negligence Complaint for a Personal Injury Case with Element-to-Fact Map
Drafts a negligence complaint from your facts, with every allegation traced to a supplied fact, each element mapped to its supporting paragraphs, and a gap table for elements with no fact behind them.
The Prompt
Variables (8)
| Variable | Description | Example |
|---|---|---|
| {{court_and_jurisdiction}} | Court and Jurisdiction | Superior Court of Arizona, Maricopa County (state court) |
| {{governing_pleading_rules}} | Governing Pleading Rules | Arizona Rules of Civil Procedure, Rules 8 and 10 (text pasted below); local rule on caption format; no dollar amount may be stated in the complaint, tier designation required. |
| {{plaintiff_name}} | Plaintiff Name | Maria Gonzalez |
| {{defendant_names_and_roles}} | Defendant Names and Roles | Daniel Reyes (driver of the delivery van); Sunline Logistics LLC (employer and registered owner of the van) |
| {{causes_of_action_and_elements}} | Causes of Action and Elements | Count 1 negligence against Reyes: duty, breach, causation, damages. Count 2 vicarious liability against Sunline: employment relationship, conduct within course and scope. |
| {{supplied_authority}} | Verified Authority to Cite | None. Do not cite authority in this draft. |
| {{case_facts}} | Case Facts with Sources | Crash report no. 24-118733 dated 03/14/2025, p. 2: Unit 1 (Reyes) "failed to stop for red signal." Witness statement of T. Alvarez dated 03/20/2025: "the van never slowed down." Client intake 03/18/2025: traveling north on 7th Street on a green light. |
| {{injuries_and_damages}} | Injuries and Damages | ER visit 03/14/2025, Banner bill $8,420.00; MRI 04/02/2025 $2,150.00: C5-C6 disc herniation; 24 PT visits $4,800.00; missed 6 weeks of work at $1,150.00 per week per employer letter dated 05/01/2025. |
Expected Output
Two parts. Part 1, attorney-only notes: (A) a numbered fact register with sources; (B) conflicts between sources, both versions quoted; (C) a damages worksheet with the arithmetic recomputed line by line; (D) an element map; (E) a gap table; (F) unsupported statements declined; (G) declined requests; (H) missing information. Part 2, the complaint: caption, parties, numbered allegations, counts and damages allegations, with "TO BE COMPLETED BY ATTORNEY" wherever a point is unresolved. A verification list closes the output.
Usage Notes
Use once intake, the incident report and the first medical records are in hand. Supply the elements of each count and the pleading rules of your court yourself: the prompt refuses to state them from memory, pleads no dollar figure without a pasted rule allowing it, adds no jury demand, interest or fee request you did not ask for, and leaves a count blank when you give no elements. Where two records disagree on a date or on the name of a party, the paragraph is left for you rather than pleaded on one version. A drafting note such as "allege he was texting" is treated as an instruction, not a fact: it lands in the gap table until you add a source. Failure mode to watch for: an allegation that reads well but rests on a third-party statement pleaded as first-hand fact; check the element map and the conflicts section before signing, and fill every "TO BE COMPLETED BY ATTORNEY" line. The listed federal rules are background only and do not govern a state-court filing. Read the document part line by line before it leaves the office: in testing, a small model sometimes left an internal remark, a comparison with the file or an unresolved point inside the document despite the instructions. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Double-check before use
- Check that the numbered paragraphs carry no source annotation and no dollar figure your pleading rule does not allow.
These are the places where this prompt was seen to slip when tested on sample cases with a small AI model.
Legal Sources Referenced
- Fed. R. Civ. P. 8(a) (a pleading stating a claim must contain a short and plain statement of the grounds for jurisdiction, a short and plain statement of the claim showing the pleader is entitled to relief, and a demand for the relief sought)
- Fed. R. Civ. P. 11(b)(3) (by presenting a pleading, the attorney certifies that the factual contentions have evidentiary support or, if specifically so identified, will likely have it after further investigation or discovery)
Originally featured in: AI for Personal Injury Lawyers: Prompts for Demand Letters, Medical Summaries & Depositions
Related Prompts
Personal Injury Demand Letter Damages Section From Your Documented Figures
Builds the damages section of a PI demand letter from the bills, wage documents and future-care support you paste. Totals are recomputed, undocumented items are excluded, and non-economic damages use only the method and figures you supply.
AI Prompt: Requests for Production to the Defendant in Personal Injury Cases
Draft personal injury requests for production to the defendant from your own case facts, with definitions, protective-order flags and a count check against the rules you paste.
AI Prompt: Soft Tissue Injury Demand Letter with a Vulnerable Plaintiff
Draft a soft tissue demand letter answering minor-damage, treatment-gap and prior-condition objections from the records, with the aggravation rule taken only from text you paste.
Pain and Suffering Daily-Life Impact Narrative for a PI Demand Package
Turns client interview notes, a symptom diary and witness statements into a specific before/after narrative of daily-life impact for a demand package. Every sentence is traceable to a source, tied to dated records where they exist, with no unsupported adjectives and no dollar figure.
* These prompts are drafting and analysis aids for licensed attorneys. They are not legal advice and do not replace professional judgment. AI output can contain errors, including invented citations and incorrect deadlines: verify every fact, figure, authority and deadline against primary sources before relying on it. Rules vary by jurisdiction, and you remain responsible for the final work product.