dischargeability-complaint
Drafts a U.S. bankruptcy adversary complaint under 11 U.S.C. §523 to determine non-dischargeability of debt. Use when a creditor, assignee, or subrogee needs a complaint for Bankruptcy Court with §523 theories (fraud, fiduciary defalcation, willful/malicious injury). Trigger when inputs include debtor case data, petition/§341 dates, transaction facts, and target §523 subsections.
Best use case
dischargeability-complaint is best used when you need a repeatable AI agent workflow instead of a one-off prompt.
Drafts a U.S. bankruptcy adversary complaint under 11 U.S.C. §523 to determine non-dischargeability of debt. Use when a creditor, assignee, or subrogee needs a complaint for Bankruptcy Court with §523 theories (fraud, fiduciary defalcation, willful/malicious injury). Trigger when inputs include debtor case data, petition/§341 dates, transaction facts, and target §523 subsections.
Teams using dischargeability-complaint should expect a more consistent output, faster repeated execution, less prompt rewriting.
When to use this skill
- You want a reusable workflow that can be run more than once with consistent structure.
When not to use this skill
- You only need a quick one-off answer and do not need a reusable workflow.
- You cannot install or maintain the underlying files, dependencies, or repository context.
Installation
Claude Code / Cursor / Codex
Manual Installation
- Download SKILL.md from GitHub
- Place it in
.claude/skills/dischargeability-complaint/SKILL.mdinside your project - Restart your AI agent — it will auto-discover the skill
How dischargeability-complaint Compares
| Feature / Agent | dischargeability-complaint | Standard Approach |
|---|---|---|
| Platform Support | Not specified | Limited / Varies |
| Context Awareness | High | Baseline |
| Installation Complexity | Unknown | N/A |
Frequently Asked Questions
What does this skill do?
Drafts a U.S. bankruptcy adversary complaint under 11 U.S.C. §523 to determine non-dischargeability of debt. Use when a creditor, assignee, or subrogee needs a complaint for Bankruptcy Court with §523 theories (fraud, fiduciary defalcation, willful/malicious injury). Trigger when inputs include debtor case data, petition/§341 dates, transaction facts, and target §523 subsections.
Where can I find the source code?
You can find the source code on GitHub using the link provided at the top of the page.
SKILL.md Source
# Dischargeability Complaint Drafts a court-ready adversary complaint under 11 U.S.C. §523 for U.S. bankruptcy proceedings, with jurisdiction/venue allegations, evidence-anchored counts, and FRBP compliance. ## Quick Start Collect before drafting: - **Standing**: Plaintiff's enforcement right (original creditor, assignee, successor, subrogee) - **Case data**: Court, case number, chapter, petition date, first §341 date, conversion status - **Deadline posture**: FRBP 4007(c) timing — confirm filing window or extension basis - **Evidence**: Contracts, account records, correspondence, payment history, admissions, fiduciary documents - **§523 theories**: Map each subsection to its required elements under controlling circuit law - **Damages**: Principal, contractual interest, statutory interest, fees, costs - **Local rules**: Caption format, paragraph style, line numbering, font/margins, filing protocol ## Core Workflow ### 1. Build complaint scaffold | Section | Content | Verify | |---|---|---| | Caption | Court name, bankruptcy case no., adversary caption, parties | District matches debtor case | | Jurisdiction/Venue | 28 U.S.C. §§1334, 157(b)(2)(I), 1409; core proceeding | Explicitly alleged | | Parties | Names, addresses, standing chain | Standing complete | | Procedural posture | Petition date, §341 date, Rule 4007(c) timing | Within deadline or extension stated | | Factual narrative | Chronological facts with dates and sources | Each allegation tied to exhibit | | Counts | Per-theory allegations for each §523 subsection | All elements and remedies included | | Prayer | Non-dischargeability, amount, interest, fees, costs | Amounts traceable to evidence | | Verification | Perjury statement and signature block | Authorized signer confirmed | | Service checklist | Filing-ready package | Complete | ### 2. Plead theory-specific elements | Theory | Elements | Style | |---|---|---| | §523(a)(2)(A) | False representation, scienter, reliance, proximate causation, damages | Fact-dense: who/what/when/where/how | | §523(a)(2)(B) | Materially untrue financial statement | Attach supporting financials, explain materiality | | §523(a)(4) | Express fiduciary relationship, breach, fraud/defalcation | Distinguish express fiduciary duty from contractual/statutory | | §523(a)(6) | Willful and malicious injury | Show intentional conduct + substantial certainty of harm | ### 3. Apply paragraph construction rules - Number all paragraphs; keep short-to-medium length for readability. - Fraud allegations must satisfy Rule 9(b): identify statement, communicator, medium, date, and falsity. - Incorporate prior paragraphs by reference at each count's start. - Use separate counts per theory — prevents collapse if one fails. - Cross-reference facts; do not repeat full blocks. ### 4. Produce mandatory sections 1. Complaint heading and title 2. Jurisdiction and venue 3. Parties / standing 4. Factual background 5. Procedural timing 6. Count I: §523(a)(2)(A) 7. Count II: §523(a)(4) *(if applicable)* 8. Count III: §523(a)(6) *(if applicable)* 9. Prayer for relief 10. Verification 11. Signature block 12. Service/filing checklist ## Legal Constraints - **FRBP 7001**: Adversary proceeding form governs structure. - **FRBP 7009 / Rule 9(b)**: Heightened pleading for fraud allegations. - **FRBP 7012 / Rule 12(b)(6)**: Frame for plausibility to resist dismissal. - **FRCP 11**: Remove weak, conclusory, or unsupported allegations — sanctions exposure. ## Pitfalls and Checks - Reconcile all damages figures against attached evidence. - Confirm every element has at least one direct fact anchor. - No allegation may rest on speculation — separate facts from legal inference. - Do not mix circuit authority; use only jurisdiction-verified standards. - Do not plead causes outside §523 scope. - Keep tone objective — factual allegations only, no inflammatory language. - Include `[VERIFY]` placeholders for unresolved legal standards or local-rule citations. - Confirm attorney signature, bar status, and filing authorization before finalizing. - Preserve exhibit organization and authentication trail. ---
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