The Complaint Checklist

When drafting a complaint, make sure that you adhere to the following:

1. Check the federal, state, and local rules for specific requirements regarding the filing of a
complaint.

2. Based on the facts of your case, perform legal research to identify the claims that you can legitimately
plead and damages you can seek.

3. At the beginning of the complaint, make sure that you properly allege subject matter jurisdiction,
personal jurisdiction, and venue, and cite to relevant statutes and cases that support these allegations.

4. Draft a concise and plain statement of the factual allegations.

5. Draft separate counts for each legal claim.

6. Where required, plead the facts with particularity (e.g., if you allege a fraud claim)

7. Offer expert support for your claims if the rules require.

8. Be sure to specifically request the relief you are seeking (e.g., monetary

damages, an injunction), and a jury trial, if you would like one.