skills/opposite-party-reply-drafter/SKILL.md

---
name: opposite-party-reply-drafter
description: Drafts a reply or written statement to a consumer complaint on behalf of the opposite party — raising any threshold objection prominently, then addressing each allegation as admitted, denied with the client's own account, denied for insufficient knowledge, or qualified. Use this whenever a user has been served a consumer complaint and needs to respond — including phrasings like "draft our reply to this consumer complaint", "prepare a written statement denying these allegations", "we've been named as opposite party, help us respond", "raise a jurisdiction objection and reply on the merits", or "draft our defence before the deadline in this complaint". Side-specific — drafted for the respondent, against the complainant. The consumer-forum counterpart to notice-reply-drafter. Fires for any reply to a consumer complaint, in any jurisdiction with a consumer-forum or equivalent process.
---

# Opposite Party Reply Drafter

## What this does

Drafts the opposite party's reply to a consumer complaint: any threshold objection — jurisdiction, limitation, maintainability — raised prominently, then a response to every allegation, admitting, denying with the client's own account, denying for insufficient knowledge, or qualifying, exactly as the client instructs. It structures what the client actually says; it does not invent a defence or a fact the client has not given.

## Before you start

**The complaint being replied to.** The actual text — there is no reply to draft without seeing exactly what was alleged.

**The client's actual position on each allegation.** What is true, false, or partially true, from the client. This is blocking; the skill structures the client's account, it does not construct a defence from the allegations alone.

**Which forum this reply is being filed before.** This affects format, procedural convention, and reply-timing rules. Ask; flag if not confirmed.

Not blocking, ask once and proceed on what is instructed: **whether jurisdiction or limitation is being challenged as a threshold objection.** If so, this should be raised prominently and early rather than folded into the allegation-by-allegation response — ask so it can be structured that way from the start.

## Method

**1. Read the whole complaint once before drafting anything.** A global point — lack of jurisdiction, limitation, non-joinder or mis-joinder of parties, the complaint not being maintainable in the form filed — can dispose of several allegations at once, and drafting allegation-by-allegation on a first pass misses this.

**2. Raise any threshold objection first and prominently**, if the client wants one raised. Note that raising a threshold objection does not require abandoning a reply on the merits — a reply can do both, reserving the objection while still addressing the allegations.

**3. List every allegation or numbered paragraph of the complaint before drafting any response**, matching the complaint's own numbering, so completeness can be checked directly against it.

**4. State the client's position on each allegation precisely, using only what the client has instructed** — admitted, denied with the client's own account, denied for insufficient knowledge to admit or deny, or qualified. Do not invent a fact or a defence to fill a gap in the client's instructions.

**5. Where an allegation is denied, give the client's own account of what happened, not a bare denial.** A bare denial carries less weight than a denial coupled with an affirmative account.

**6. Keep factual admissions separate from legal characterisation.** Admitting that an item was delivered five days late is not the same as admitting deficiency in service — concede the fact if it is true, without conceding the legal conclusion the complainant draws from it.

**7. State the client's own case or defence at the end** — what actually happened from their side, and any specific defence such as misuse, unauthorised modification, or a cause outside their control — only as instructed by the client, never invented to fill a gap.

**8. Flag reply-timing or format requirements specific to the forum as a verification point** rather than assuming compliance.

## Output

**1. Header.** Forum, complaint reference, opposite party (respondent) and complainant, date.

**2. Preliminary objections, if any.** Jurisdiction, limitation, or maintainability, stated prominently and first.

**3. Reply to allegations.** Numbered to match the complaint: admitted / denied with the client's own account / denied for insufficient knowledge / qualified.

**4. Client's own case or defence.**

**5. Relief sought.** Dismissal of the complaint, costs, or other relief, only as instructed.

**6. Points requiring verification.** Forum-specific reply-timing or format rules, and anything resting on an unconfirmed legal characterisation.

## Do not

Do not invent a fact or defence the client has not actually given.

Do not concede a legal conclusion — deficiency, unfair trade practice — while admitting an underlying fact. Keep the two separate throughout.

Do not omit a threshold objection the client wants raised, and do not bury it inside the allegation-by-allegation response.

Do not assume reply-timing or format compliance with the forum's rules. Flag it as a point to verify.

Do not leave an allegation unaddressed without flagging the risk to the user.