skills/pleadings-analyst/SKILL.md

---
name: pleadings-analyst
description: >-
  Analyse claims, defences, replies, counterclaims, amendments, and particulars
  for causes of action, admissions, denials, inconsistencies, missing facts,
  affirmative defences, burdens, and issues for determination. Use during early
  case assessment, amendment, disclosure, witness preparation, or trial planning.
---

# Pleadings Analyst

Read the operative pleadings paragraph by paragraph and preserve the difference
between allegation, admission, denial, non-admission, positive case, and evidence.

## Intake

Obtain the jurisdiction and forum, all pleading versions, filing and service
dates, orders and amendments, causes of action and relief, contracts or statutes
incorporated by reference, particulars, admissions, procedural rules, limitation
position, and the client's current factual instructions.

## Analysis method

1. Identify the operative version, parties, capacities, jurisdictional basis,
   procedural posture, verification, and relief claimed.
2. Break each cause, defence, counterclaim, and reply into required elements,
   burden, standard, and pleaded material facts.
3. Map every numbered allegation to the responsive paragraph and classify the
   response as admission, partial admission, denial, non-admission, avoidance,
   inconsistent alternative, or no response.
4. Distinguish a material fact from evidence, law, submission, conclusion, and remedy.
5. Identify missing elements, inadequate particulars, ambiguity, internal
   contradiction, impermissible general denial, departure, new matter, and
   inconsistency across related proceedings.
6. Record formal and deemed admissions, concessions, notices to admit, and facts
   not genuinely disputed, subject to current forum rules.
7. Test standing, capacity, jurisdiction, limitation, conditions precedent,
   causation, loss, mitigation, affirmative defences, set-off, contribution,
   counterclaim, and available relief.
8. Link each live factual proposition to evidence, witness, disclosure request,
   expert issue, and evidential gap.
9. Identify amendment, strike-out, summary disposition, particulars, reply,
   joinder, bifurcation, or issue-narrowing options without assuming availability.
10. Draft neutral issues for determination that reflect both parties' cases.

## Output

Provide a pleading map, element-and-burden table, admission and denial schedule,
inconsistency list, missing-fact and particulars list, live-issue matrix,
evidence and disclosure plan, and procedural recommendations.

## Guardrails

Do not treat allegation as evidence, silence as admission without a verified
rule, or alternative pleading as factual dishonesty. Do not overlook superseded
versions, amendments, privilege, confidentiality, sanctions, or verification
duties. Confirm local pleading standards and deadlines before action.