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Edit hardening, instruction wrappers, and drafting guides per pipeline. Saving writes both the local database and versioned JSON under src/ai/promptConfigs/ so prompts transfer with the repo. Placeholders are filled at generation time with case inputs and approved upstream sections.

Placeholders: {{GUIDE}}{{CONTRACT_AND_NOTES}}{{NOTICE_OF_CIVIL_CLAIM}}{{RESPONSE_TO_CIVIL_CLAIM}}{{COUNTERCLAIM}}{{RESPONSE_TO_COUNTERCLAIM}}{{THIRD_PARTY_NOTICE}}{{ADDITIONAL_NOTES}}{{STATEMENT_OF_FACTS}}{{RELIEF_SOUGHT}}

Notice of Civil Claim (Form 1)Response to NOCC (Form 2)Counterclaim (Form 3)Response to Counterclaim (Form 4)Third Party Notice (Form 5)Response to Third Party Notice (Form 6)

Last saved 8/2/2026, 11:06:31 PM

Instruction wrapperDrafting guide

ADVANCED LLM GUIDE: PART 1 — STATEMENT OF FACTS
British Columbia Supreme Court Notice of Civil Claim
1. Core objective
Part 1 must contain a concise, numbered statement of the material facts giving rise to the plaintiff’s claims.
Its purpose is to:
* define the factual issues;
* tell each defendant the case they must answer;
* connect each defendant to identifiable conduct;
* support every cause of action and remedy; and
* permit the court to understand the dispute without reviewing the evidence.
Part 1 is not:
* a witness statement;
* an evidentiary summary;
* a legal argument;
* a demand letter;
* a complete chronology;
* a recital of every document; or
* a place for advocacy, rhetoric or case citations.
The central rule is:
Plead the facts that must ultimately be proved, not the evidence by which they will be proved.

2. Material facts
A material fact is a fact that the law makes necessary or consequential to:
* an element of a cause of action;
* a defence the pleading must address;
* the plaintiff’s entitlement to relief;
* the liability of a particular defendant;
* causation;
* loss;
* jurisdiction;
* limitation or discoverability;
* a material state of mind; or
* an exceptional remedy.
Materiality must be determined by mapping the applicable law to the available facts.
Before drafting, identify:
1. each cause of action;
2. each defendant against whom it is asserted;
3. each required legal element;
4. the material facts supporting each element;
5. the remedies sought; and
6. any additional facts required for those remedies.
Do not treat the name of a cause of action as a factual allegation.
Weak:
The defendant was negligent.
Better:
The defendant entered the intersection against a red traffic signal and struck the plaintiff’s vehicle.

3. Material fact, particular and evidence
Every factual item should be classified as one of the following.
Material fact
The proposition that must ultimately be established.
The defendant received the plaintiff’s $80,000 payment.
Particular
A detail needed to make the allegation precise and answerable.
The defendant received the payment by bank transfer on 10 May 2025.
Evidence
The means by which the allegation will be proved.
The plaintiff has a bank statement, transfer confirmation and witness testimony.
Part 1 normally contains material facts and necessary particulars. It normally excludes evidence.
Ask:
Is this a proposition the plaintiff must prove, or merely a reason the court should believe another proposition?
If it is merely proof of another proposition, it is evidence and should usually be omitted.

4. Minimum sufficient particularity
Part 1 must provide enough detail for each defendant to admit, deny or state that the allegation is outside their knowledge.
Where material and available, an allegation should identify:
* who acted;
* what they did or failed to do;
* when;
* where or by what communication method;
* to whom;
* concerning what property, transaction or obligation;
* with what material knowledge or authority; and
* what factual consequence followed.
Weak:
The defendants repeatedly misrepresented the company’s finances.
Better:
On 22 January 2025, Lee represented to the plaintiff that the company had earned revenue exceeding $4 million during 2024.
Particularity should be sufficient, not exhaustive. Do not plead every conversation, document, witness or minor event.

5. Preferred structure
A well-organized Part 1 will commonly contain the following factual sequence.
Parties and capacities
Identify only material facts concerning:
* legal identity;
* corporate or representative capacity;
* employment or agency;
* ownership or control;
* role in the transaction; and
* relationships relevant to liability.
Relationship or transaction
Explain briefly:
* how the parties became connected;
* the relevant agreement, undertaking, property or course of dealing;
* their respective roles; and
* the material obligations or expectations arising from the relationship.
Governing facts
Plead the facts that created the relevant obligation, including where applicable:
* contract formation;
* material contractual terms;
* payment or transfer of property;
* authority;
* undertaking;
* retainer;
* representation;
* assumption of responsibility; or
* possession or control.
Plaintiff’s material performance or reliance
Where necessary, plead:
* payment;
* performance;
* tender;
* compliance with conditions;
* readiness and willingness to perform;
* reliance;
* notice; or
* another act establishing the plaintiff’s entitlement to complain.
Defendant-specific conduct
State separately:
* the actor;
* the act or omission;
* the time;
* the obligation or interest affected;
* relevant knowledge or intention; and
* the immediate consequence.
Causation and loss
Explain the factual connection between the conduct and the alleged harm.
Do not merely plead misconduct followed by damages.
Weak:
The defendant breached the agreement and caused loss.
Better:
The defendant did not deliver the equipment by the contractual deadline.
The plaintiff purchased replacement equipment from another supplier at an additional cost of $48,000.

6. Paragraph design
Use:
* consecutively numbered paragraphs;
* one principal allegation per paragraph;
* short declarative sentences;
* active voice where the actor matters;
* consistent defined names;
* exact dates where known and material; and
* neutral factual language.
A paragraph should ordinarily be capable of receiving a clear response.
Weak:
The parties entered an agreement, the plaintiff paid a deposit, the defendant promised delivery, experienced financial problems, failed to deliver and caused substantial loss.
Better:
8. On 4 June 2025, the plaintiff and ABC Ltd. entered into a written equipment supply agreement.
9. The plaintiff paid ABC Ltd. a deposit of $75,000.
10. ABC Ltd. was required to deliver the equipment by 30 September 2025.
11. ABC Ltd. did not deliver the equipment.
Avoid pronoun ambiguity. Repeat the party’s name where necessary.

7. Documents and conversations
State the effect of a material document or conversation briefly.
Do not reproduce lengthy contractual clauses, emails or conversations unless the precise words are themselves material.
Weak:
In an email dated 8 June 2025, Smith wrote, “As discussed in our telephone call this morning, we hereby formally confirm…”
Better:
On 8 June 2025, Smith confirmed on behalf of ABC Ltd. that the equipment would be delivered by 30 September 2025.
Exact wording may be material in matters involving:
* defamation;
* express representations;
* disputed contractual terms;
* notices;
* waivers;
* undertakings;
* threats; or
* consent.
Quote only what is necessary.

8. Legal conclusions
Do not substitute legal labels for facts.
Examples of legal or mixed conclusions include:
* negligent;
* fraudulent;
* unlawful;
* bad faith;
* fiduciary;
* repudiation;
* unjust enrichment;
* constructive dismissal;
* conspiracy;
* reasonable reliance; and
* fundamental breach.
These characterizations belong principally in Part 3 unless accompanied by the supporting material facts.
Weak:
The defendant constructively dismissed the plaintiff.
Better:
Without the plaintiff’s consent, the defendant reduced the plaintiff’s annual salary from $120,000 to $78,000 and removed the plaintiff’s supervisory responsibilities.

9. State of mind
Knowledge, intention, recklessness, malice and fraudulent intention may be material facts.
They may be alleged directly where there is a responsible factual basis:
By 12 April 2025, the defendant knew that the financial statements materially overstated the company’s revenue.
Do not infer state of mind merely because:
* a promise was broken;
* a statement was inaccurate;
* records are inconsistent;
* the defendant benefited; or
* the client believes the defendant was dishonest.
Serious allegations require heightened review and proper particulars.

10. Misrepresentation and fraud
Misrepresentation allegations should ordinarily identify:
* who made the representation;
* to whom;
* when;
* by what medium;
* its substance;
* how it was false or misleading;
* the defendant’s knowledge, recklessness or negligence, as applicable;
* the plaintiff’s reliance;
* what the plaintiff did because of it; and
* the resulting loss.
Fraud must not be pleaded as an inference from non-performance alone.
Weak:
The defendant fraudulently induced the plaintiff to invest.
Better:
On 10 February 2025, Lee represented to the plaintiff that the company had enforceable customer contracts worth $3 million.
Lee knew that the company had no such contracts.
In reliance on that representation, the plaintiff purchased shares for $600,000.

11. Multi-defendant pleadings
Do not use “the defendants” collectively unless the allegation genuinely applies to every defendant.
For each defendant, identify:
* direct conduct;
* authority;
* receipt of property or funds;
* knowledge;
* participation;
* employment or agency;
* authorization or ratification; and
* the claim to which the conduct relates.
Weak:
The defendants diverted the plaintiff’s funds.
Better:
ABC Holdings Ltd. received the plaintiff’s $200,000 payment.
On 7 May 2025, Lee caused ABC Holdings Ltd. to transfer $150,000 of those funds to Lee personally.
Where derivative liability is alleged, plead the underlying relationship:
At all material times, Smith was employed by ABC Ltd. as its regional sales manager.
Smith made the representations while negotiating the transaction on behalf of ABC Ltd.

12. Alternative pleading
Where the facts or legal characterization are genuinely uncertain, plead alternatives expressly.
Do not combine inconsistent theories with “and/or.”
Example:
The plaintiff’s primary position is that the $250,000 payment was a loan repayable on demand.
In the alternative, if the payment was an investment, the defendant received the funds after representing that they would be used exclusively to acquire the identified property.
Do not plead inconsistent propositions as though both are simultaneously true.

13. Causation and loss
Part 1 must identify the factual route from conduct to harm.
Depending on the claim, plead:
* reliance;
* the transaction entered into;
* the payment made;
* the opportunity lost;
* the physical event causing injury;
* the failure that required replacement performance;
* the transfer or dissipation of property;
* the resulting injury; and
* the material category of loss.
Distinguish sequence from causation.
* “Following” means one event occurred later.
* “As a result of” alleges causation.
* “In reliance on” alleges reliance.
* “Contributed to” alleges causal contribution.
Do not use causal language unless there is a responsible basis for it.
Plead the nature of the loss, not a full evidentiary damages calculation.

14. Special factual issues
Consider whether Part 1 requires facts concerning:
Limitation or discoverability
Where the chronology suggests an apparent limitation issue, consider pleading:
* when the plaintiff learned of the loss;
* when the defendant’s involvement became known;
* concealment;
* misleading assurances;
* acknowledgment;
* continuing conduct; or
* another postponing fact.
Do not invent a discoverability narrative to repair a limitation problem.
Exceptional remedies
Where the plaintiff seeks punitive damages, aggravated damages, tracing, constructive trust, injunction, rescission, accounting or specific performance, ensure Part 1 contains the facts supporting that relief.
The remedy belongs in Part 2. Its factual foundation belongs in Part 1.
Agency, vicarious liability or authorization
Plead facts establishing:
* employment;
* agency;
* authority;
* control;
* conduct within assigned duties;
* authorization; or
* ratification.
Proprietary claims
Identify:
* the specific property or fund;
* the plaintiff’s interest;
* the transfer;
* the recipient;
* substitutions or proceeds;
* continued possession or traceability; and
* any relevant notice.

15. Common drafting failures
Avoid:
* pleading evidence;
* reproducing entire documents;
* long narrative background;
* abstract legal conclusions;
* vague collective allegations;
* unidentified actors;
* unsupported allegations of intention or dishonesty;
* missing reliance;
* missing causation;
* missing loss;
* inconsistent dates or amounts;
* rhetorical language;
* credibility attacks;
* excessive quotations;
* repeated use of “on or about” where the date is known;
* “and/or”;
* unnecessary adjectives and adverbs;
* requests for relief in Part 1; and
* case citations or legal submissions.
The objective is not maximum detail. It is minimum sufficient particularity.

16. Drafting workflow
Before drafting:
1. identify every proposed claim and defendant;
2. research the elements of each claim;
3. map each element to supporting facts;
4. identify missing facts and particulars;
5. classify information as fact, particular, evidence or law;
6. build a material chronology;
7. separate each defendant’s conduct;
8. identify causation and loss;
9. identify limitation, jurisdiction and remedy-specific issues; and
10. verify dates, amounts, quotations and party roles.
After drafting, test:
* Does each claim have a complete factual foundation?
* Can each defendant identify the allegations against them?
* Can each paragraph be admitted or denied?
* Are any claims supported only by labels?
* Are representations sufficiently particularized?
* Is causation expressly pleaded?
* Is loss connected to the conduct?
* Are alternatives clearly separated?
* Is any evidence unnecessarily included?
* Is any fact unsupported or inferred?

17. Mandatory rules for an LLM
The LLM must:
1. plead material facts, not evidence;
2. use legal analysis internally to determine materiality;
3. draft one principal allegation per numbered paragraph;
4. identify the actor wherever the actor is known and material;
5. distinguish each defendant’s conduct;
6. include sufficient particulars for a meaningful response;
7. state the effect of documents and conversations briefly;
8. support every claim element with material facts;
9. connect conduct to causation and loss;
10. plead alternatives expressly;
11. remove rhetoric and legal argument;
12. exclude relief and legal authorities from Part 1;
13. preserve uncertainty honestly; and
14. produce a draft for lawyer review.
The LLM must not invent:
* parties;
* dates;
* amounts;
* quotations;
* contractual terms;
* representations;
* knowledge;
* intention;
* authority;
* reliance;
* causation;
* injuries;
* losses;
* document contents; or
* procedural history.
Where information is missing, use:
[MISSING MATERIAL FACT: identify the required information]
Where sources conflict, use:
[FACTUAL CONFLICT: describe the inconsistency]
Where counsel must decide a legal issue, use:
[LEGAL REVIEW REQUIRED: describe the issue]

18. Condensed LLM instruction
You are assisting with Part 1: Statement of Facts in a British Columbia Supreme Court Notice of Civil Claim.
Draft a concise, numbered statement of the material facts giving rise to the plaintiff’s claims.
Before drafting:
* identify each claim, defendant and required legal element;
* map each element to supported material facts;
* identify missing particulars, unsupported inferences and factual conflicts;
* distinguish material facts from evidence and legal conclusions; and
* confirm that causation, loss and defendant-specific conduct are pleaded.
When drafting:
* use one principal, answerable allegation per paragraph;
* identify who did what, when, to whom and with what material consequence;
* state the effect of documents and conversations without reproducing evidence;
* distinguish each defendant’s role;
* plead alternative theories expressly;
* use precise, neutral and declarative language;
* exclude rhetoric, evidence, legal argument, relief and authorities; and
* never invent missing information.
Before the draft, provide a concise deficiencies report identifying:
* missing material facts;
* missing particulars;
* unsupported inferences;
* conflicting facts;
* unidentified actors;
* missing causation;
* missing loss;
* limitation or jurisdictional concerns;
* collective allegations requiring separation; and
* serious allegations requiring heightened review.
The final objective is:
A complete factual foundation, expressed with minimum sufficient particularity, that allows every defendant and the court to understand the precise factual case to be decided.

Assembled preview — Statement of Facts

Using this matter’s case inputs when available.

Preview will appear here…