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SDNY Rule 12(b)(6) Motion to Dismiss with Business Judgment Rule Defense

A drafting prompt for a Rule 12(b)(6) memorandum of law in the Southern District of New York invoking the business judgment rule against a fiduciary duty claim.

The Prompt

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Preview prompt structure
"You are a civil defense litigation attorney in the Southern District of New York. Draft a memorandum of law in support of a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The plaintiff alleges breach of fiduciary duty against our client, a corporate d...

Expected Output

A structured 12(b)(6) memorandum of law with Introduction, Statement of Facts, Legal Standard, Argument with sub-headings, and Conclusion.

Usage Notes

Use this as a first-draft scaffold only. The prompt explicitly tells the model not to fabricate citations — verify every legal proposition against current Second Circuit and Delaware corporate-law authority before filing.

Originally featured in: Prompt Engineering for Lawyers: The Complete 2026 Guide

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