John HenryThe platform
Motion Builder · Response Builder

A motion is a set of elements, each with a source, a burden and something that has to prove it.

So that is how it is built. You pick the forum, the relief and the theory; the elements follow from those, and the document is assembled from what you actually answered. Nothing in it asserts a fact that nobody typed into an element.

The Motion Builder — a Rule 7001 check, element cards graded by the drafter, and the authority pass disagreeing underneath in red
A real render, not a mock-up. The contested-vehicle warning on Rule 7001, then the elements — the drafter's grade on each card, the authority pass's finding underneath. The matter is invented.
The catalogue

Two registers on one card, because a beginner mode is a motion with the traps taken out.

5 forums, 46 kinds of relief, 65 theories and 187 elements — and every element carries the source it rests on, the proof it needs, a practitioner's statement of it and one plain instruction derived from the other two.

The intended reader is a managing partner with twenty years of bankruptcy practice AND the associate down the hall. A “simple mode” would mean those two people are looking at different motions, and the associate's is the one missing the parts that bite. So every element card carries the practitioner's statement, one plain instruction derived from that element's own source and proof — which means it exists for all of them and cannot drift — and the practitioner's note.

The cascade is the order a lawyer actually works in: what the case and the parties already say, then the documents on the file, then your own firm's templates on that subject, and only then a search of authority to confirm the path you already took. When your firm has no template for a subject the tool says so outright rather than reaching for somebody else's.

The one refusal

Rule 7001 is a hard stop, and it has three answers rather than two.

Fed. R. Bankr. P. 7001 lists ten proceedings that must be brought by adversary complaint. Drafting a motion for one produces a paper that is defective on its face and no amount of argument cures it — so this is the only place the builder refuses outright.

The worked example it was built on

An omnibus claim objection cannot carry a usury theory. Rule 3007(d)'s permitted grounds are a closed list and a substantive ground is not on it, 3007(e) caps at a hundred claims, and 3007(b) forbids joining Rule 7001 relief to an objection. So disallowance under § 502(b)(1) is a contested matter, recovering the excess is 7001(1), and subordinating under § 510(c) is 7001(8): one theory, three papers.

The Response Builder

A response does not choose what it is about. The movant did.

So there is no relief picker. The elements are the movant's, read off the relief they served, and what you supply for each is a POSTURE — denied, disputed on the facts, admitted, legally insufficient, affirmative defence, or no position.

Building it the obvious way, with a relief chooser, produces a tool that drafts a cross-motion every time somebody meant to file an objection. And there is no default posture: a default of “deny” would have the software take a litigation position, and would make an untouched response look like a complete denial of everything.

Asking for something back is a cross-motion

Whatever the caption says. Buried in a response it gets no notice period of its own and no hearing convened for it — so affirmative relief is refused, and the refusal names the second document you actually need. An affirmative defence is NOT a cross-motion, and keeping those apart is the point: a check that flagged every limitations defence would be switched off inside a week, and then the real refusal would not reach anybody either.

Deadlines

Two rules, seven days apart, and the comparison is the warning.

In the Northern District of Texas, Local Rule 9007-1 gives fourteen days where the motion carries a negative-notice legend, and 9013-1 gives twenty-one for an ordinary opposed motion. The legend says relief is granted WITHOUT A HEARING if nobody objects in time, so the shorter window is the one with teeth — and a response calendared off the twenty-one-day rule against a negative-notice motion arrives after the order.

Both numbers are always shown together. The page asks which applies and reads “not known yet” until somebody answers, because a default there is the tool guessing at the one number it must not guess at. Both were read out of the court's own PDF and are re-checked monthly against a content hash; a change raises a row on the board rather than overwriting quietly.

Drop a served pleading in and the caption reader will find the legend for you — it requires two independent phrases rather than one, so a motion that happens to mention acting without further notice about something unrelated is not handed a deadline it does not have. Finding the legend does not SET the deadline. The parser's job ends at “these words are on the page”; what they do to a date is a legal consequence and a separate function.

The document

Nothing in the paper asserts something no element carries.

Every factual sentence in the generated motion is one somebody typed into an element, quoted back. A generator that writes connective prose writes assertions, and an assertion nothing in the record supports is a Rule 9011 problem with your name under it.

An unanswered element is PRINTED, as a bracketed gap carrying its own instruction — never omitted. A motion missing its third element and one that never needed a third look identical on paper, and only one of those is finished. Word and PDF, Letter, one-inch margins, Times New Roman 12, and 28 U.S.C. § 1746's fixed perjury wording written out in full — while local form is a marked gap that names the rule and says it is unconfirmed. A text may be asserted; a local practice may not.

Outcomes attach to elements rather than to motions, because “this element carried, on this evidence, before this judge, over this objection” is the reusable fact. A denial for want of a certificate of service says nothing about the motion, so preventable defects are a separate column excluded from every merits rate and reported as their own number.

The part other vendors leave out

And here is what it refuses to do.

Read this before the feature list, not after it.

Nothing files and nothing signs.

There is no CM/ECF integration and there is no e-signature. Recording a motion as filed is a snapshot you take after you filed it yourself. A tool that files is a tool that can file the wrong thing at 4:59 on a Friday.

No case ever goes green off a model.

A model may assert a TEXT — a statute, a national rule — because you can confirm it in fifteen seconds against a free authoritative source. It may never settle what a case HELD. A case citation from a model pass tops out at arguable, and the ceiling is enforced where the card is stored rather than asked for in a prompt, because a rule a model is asked to follow is a rule it can fail to follow silently.

The sources it cannot reach are listed, switched off, by name.

The research panel names the judges' standing procedures, the docket and the full text of the decisions, and says NOT CONNECTED beside each. A panel that lists only what a tool has tells you it consulted everything it has.

It will not give you a deadline as a date.

It returns a number of days and the rule the number came from, and where two local rules answer differently it shows both, because the comparison is the warning. Rule 9006 counting, service-method additions and court holidays are not modelled, and a date printed with confidence is one a lawyer stops re-checking.

It does not read a scan.

A served pleading with no text layer is reported as probably a scan, which is not the same claim as the document being empty. The caption in a picture is a picture.

It will not take a litigation position for you.

A response has no default posture, because a default of deny would make an untouched response read as a complete denial of everything. Whether a matter is core and whether you consent to entry of a final order are left blank — that is Stern v. Marshall, and it is a position, not a recital.

It never says a case is good law.

A citation graph proves that one case cited another on a date. It cannot tell overruled from distinguished from a string cite, and anything that renders a green flag off a citation count is the failure this whole system is built against.

It bills no time you did not spend.

Model seconds are stored as telemetry in a column the schema will not allow to be summed into a billable line — a generated column that cannot reference it, with a probe that fails the build if it ever does. ABA Formal Op. 512 and Tex. Ethics Op. 705 both hold that only human time is billable; here that is unrepresentable rather than documented.

Put a real motion through it.

The fastest way to evaluate this is to build something you already know the answer to and see where it argues with you.

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