Adversary Proceeding Complaint Template

United States Bankruptcy Court
District of [District]

In re: [Debtor Name], Debtor.
Case No.: [Number]

[Plaintiff Name],
Plaintiff,

v.
[Defendant Name],
Defendant.

Adversary Proceeding No.: [To be assigned]

COMPLAINT

Plaintiff alleges:

I. Jurisdiction and Venue

1. The Court has jurisdiction under 28 U.S.C. §§ 157 and 1334.
2. This adversary proceeding is a core proceeding under 28 U.S.C. § 157(b)(2)([A/B/E/O]).
3. Venue is proper pursuant to 28 U.S.C. § 1409.

II. Parties

4. Plaintiff [Name] is [trustee/creditor/debtor] in the underlying bankruptcy case.
5. Defendant [Name] is [describe status, address].

III. Factual Background

6. On [Date], Debtor filed a petition under Chapter [ ].
7. [Describe relevant facts: transfer, debt, conduct].

IV. Claims for Relief

Count I – [e.g., Determination of Dischargeability under 11 U.S.C. § 523(a)(2)]

8. Plaintiff realleges paragraphs 1-7.
9. Defendant obtained money/property from Plaintiff by false pretenses, false representation, or actual fraud.
10. Details of misrepresentation, reliance, and damages.
11. Plaintiff seeks determination that debt is nondischargeable.

Count II – [e.g., Avoidance of Fraudulent Transfer under 11 U.S.C. § 548]

12. Plaintiff realleges paragraphs 1-7.
13. Debtor transferred property within [2] years before filing with intent to hinder, delay, or defraud creditors / for less than reasonably equivalent value while insolvent.
14. Plaintiff seeks avoidance and recovery under 11 U.S.C. §§ 548 and 550.

Additional Counts

• [Preference claim under § 547, turnover under § 542, objection to discharge under § 727, etc.]

V. Prayer for Relief

WHEREFORE, Plaintiff requests that the Court:
- Enter judgment in favor of Plaintiff on each count;
- Determine that the debt owed to Plaintiff is non-dischargeable / avoided / recovered;
- Award damages, costs, and attorneys’ fees as permitted by law; and
- Grant such other relief as the Court deems just.

VI. Jury Demand (if applicable)

15. Plaintiff demands a jury trial on issues so triable (include statement of consent to bankruptcy judge jury trial if required).

Respectfully submitted,

[Law Firm Name]

By: ________
[Attorney Name] (Bar No. [Number])
[Address]
[Phone]
[Email]

Date: [Date]