IMPORTANT: THIS IS A PREPARATION GUIDE — NOT A FILING-READY DOCUMENT

Bankruptcy court filings must comply with the Federal Rules of Bankruptcy Procedure,
local court rules, and any judge-specific requirements. This template provides
substantive legal content to help you draft — but it must be reviewed by a qualified
bankruptcy attorney and adapted to your local court's requirements before filing.
Check your district's local rules at https://www.uscourts.gov/rules-policies.

ADVERSARY PROCEEDING COMPLAINT

Table of Contents

1. Caption and Parties
2. Jurisdiction and Venue
3. Nature of Proceeding
4. Parties
5. Factual Allegations
6. Causes of Action
7. Prayer for Relief
8. Jury Demand

UNITED STATES BANKRUPTCY COURT

_____________ DISTRICT OF _____________

PART 1: CAPTION AND PARTIES

[________________________________], Plaintiff(s),

v.

[________________________________], Defendant(s).

PART 2: JURISDICTION AND VENUE

1. This Court has jurisdiction over this adversary proceeding pursuant to 28 U.S.C. §§ 157 and 1334.

2. This is a core proceeding under 28 U.S.C. § 157(b)(2), specifically:

☐ (A) Matters concerning the administration of the estate
☐ (B) Allowance or disallowance of claims
☐ (C) Counterclaims by the estate against persons filing claims
☐ (F) Proceedings to determine the dischargeability of particular debts
☐ (H) Proceedings to determine, avoid, or recover fraudulent conveyances
☐ (I) Determinations as to the dischargeability of particular debts
☐ (O) Other proceedings affecting the liquidation of the assets of the estate
☐ Other: [________________________________]

3. Venue is proper in this district under 28 U.S.C. § 1409.

PART 3: NATURE OF PROCEEDING

This adversary proceeding is filed pursuant to FRBP 7001 as a:

☐ (1) Proceeding to recover money or property (other than under § 542, § 543, § 547, § 548, § 549, or § 553(b))
☐ (2) Proceeding to determine the validity, priority, or extent of a lien or other interest in property
☐ (4) Proceeding to object to or revoke a discharge (11 U.S.C. § 727)
☐ (6) Proceeding to determine the dischargeability of a debt (11 U.S.C. § 523)
☐ (7) Proceeding to obtain an injunction or other equitable relief
☐ (8) Proceeding to subordinate any allowed claim or interest (11 U.S.C. § 510)
☐ (9) Proceeding to obtain a declaratory judgment relating to the foregoing
☐ (10) Proceeding to determine a claim or cause of action removed to bankruptcy court
☐ Avoidance Action: ☐ § 544 ☐ § 545 ☐ § 547 ☐ § 548 ☐ § 549 ☐ § 553(b)

PART 4: PARTIES

Section A: Plaintiff

Section B: Defendant

PART 5: FACTUAL ALLEGATIONS

Section A: General Background

1. On [__/__/____], [Debtor] filed a voluntary petition under Chapter [____] of the Bankruptcy Code.

2. [________________________________]

3. [________________________________]

Section B: Specific Facts Supporting Claims

For Nondischargeability (§ 523):

4. The debt at issue arises from [________________________________].

5. The amount of the debt is approximately $[________________].

6. [________________________________]

For Preference Actions (§ 547):

4. Within [____] days before the filing of the petition [90 days for non-insiders; 1 year for insiders], the Debtor transferred the following to or for the benefit of Defendant:

5. The transfer was made on account of an antecedent debt owed by the Debtor before the transfer was made.

6. The transfer was made while the Debtor was insolvent (presumed under 11 U.S.C. § 547(f) for 90 days before filing).

7. The transfer enabled the Defendant to receive more than it would have received in a Chapter 7 liquidation.

For Fraudulent Transfer (§ 548):

4. Within 2 years before the filing date, the Debtor transferred property as follows:

5. ☐ The transfer was made with actual intent to hinder, delay, or defraud creditors (§ 548(a)(1)(A)).
   ☐ The Debtor received less than reasonably equivalent value and was insolvent or became insolvent as a result (§ 548(a)(1)(B)).

PART 6: CAUSES OF ACTION

Count I: [________________________________]

[Select applicable cause of action:]

☐ Nondischargeability — Fraud (§ 523(a)(2)(A))
The debt is nondischargeable because it was obtained by false pretenses, a false representation, or actual fraud, other than a statement respecting the debtor's financial condition.

☐ Nondischargeability — Fraud in Writing (§ 523(a)(2)(B))
The debt is nondischargeable because it was obtained through a materially false written statement respecting the debtor's financial condition, on which the creditor reasonably relied.

☐ Nondischargeability — Embezzlement/Larceny (§ 523(a)(4))
The debt is nondischargeable because it was incurred through fraud or defalcation while acting in a fiduciary capacity, embezzlement, or larceny.

☐ Nondischargeability — Willful and Malicious Injury (§ 523(a)(6))
The debt is nondischargeable because it was for willful and malicious injury by the debtor to another entity or the property of another entity.

☐ Preference Avoidance (§ 547(b))
The Plaintiff seeks to avoid and recover a preferential transfer made to the Defendant within the applicable preference period.

☐ Fraudulent Transfer Avoidance (§ 548(a))
The Plaintiff seeks to avoid and recover a fraudulent transfer made within 2 years of the petition date.

☐ Denial of Discharge (§ 727(a))
The Plaintiff objects to the debtor's discharge based on: [________________________________]

☐ Other: [________________________________]

Count II: [________________________________]

[Additional causes of action as applicable]

PART 7: PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court:

☐ Enter judgment declaring that the debt owed by the Debtor to Plaintiff in the amount of $[________________] is nondischargeable under 11 U.S.C. § 523(a)([____])

☐ Enter judgment avoiding the transfer(s) described herein and directing Defendant to pay the value of the avoided transfer(s) to the estate under 11 U.S.C. § 550

☐ Deny the Debtor's discharge under 11 U.S.C. § 727(a)

☐ Enter a money judgment against Defendant in the amount of $[________________]

☐ Award Plaintiff pre-judgment and post-judgment interest

☐ Award Plaintiff costs of suit and attorneys' fees where permitted

☐ Grant such other and further relief as the Court deems just and proper

PART 8: JURY DEMAND

☐ Plaintiff demands a trial by jury on all issues so triable pursuant to 28 U.S.C. § 157(e) and Fed. R. Civ. P. 38 (incorporated by FRBP 9015).

☐ Plaintiff does not demand a jury trial.

VERIFICATION

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct to the best of my knowledge, information, and belief.

Signature: _________________________________ Date: [__/__/____]

Printed Name: _________________________________

ATTORNEY INFORMATION

Attorney Signature: _________________________________ Date: [__/__/____]

Name: _________________________________
Bar Number: _________________________________
Firm: _________________________________
Address: _________________________________
Phone: _________________________________
Email: _________________________________

DEADLINE REMINDERS

Dischargeability Complaints (§ 523(c)):
- Must be filed within 60 days after the first date set for the § 341 meeting of creditors (FRBP 4007(c))
- Extensions may be granted for cause if requested before the deadline expires

Denial of Discharge (§ 727):
- Must be filed within 60 days after the first date set for the § 341 meeting (FRBP 4004(a))

Preference/Fraudulent Transfer Actions:
- Must be commenced within 2 years after the order for relief (11 U.S.C. § 546(a))

This template provides general guidance for adversary proceeding complaints under Part VII of the FRBP. The specific allegations and causes of action must be tailored to the facts. Always verify filing deadlines and local rules.