Tear Apart the Funder's MSJ in Minutes
Upload the funder's MSJ packet. DocketDrafter reads every exhibit, flags every CPLR 4518 foundation defect, and produces a court-formatted reply brief with citations to the exact paragraphs where the problems are.
Book a 15-Minute IntroFrom MSJ Packet to Reply Brief in Minutes
Every case citation comes from your past briefs. DocketDrafter reads the full MSJ packet, applies your arguments to the new facts, and delivers a court-formatted reply.
You Know the Attacks. The Work Is Finding Them in This Packet.
200 Pages of Exhibits and Every Foundation Defect Is Buried
The proof of funding is a bank-generated ACH record, not the funder's own record. The business records affirmation uses boilerplate that references “photo, video, recording, audio recording” for a financial record. The electronic records authentication language is missing entirely. You know these attacks, but finding each one in this specific packet takes hours.
Every CPLR 4518 Defect Flagged With Citations
DocketDrafter reads every exhibit, identifies third-party records without foundation, detects boilerplate affirmation language, and checks for missing electronic records authentication. Each defect is mapped to the exact paragraph and exhibit where it appears, with the corresponding case law already applied.
The Numbers in the Complaint, Affirmation, and Bank Record Never Match
The attorney affirmation says one funded amount. The custodian affirmation says another. The actual transfer record shows a third number. Purchase price minus origination fee does not equal the wire amount. These discrepancies are material issues of fact, but finding them means cross-referencing five documents page by page.
Cross-Document Inconsistencies Surfaced Automatically
DocketDrafter compares the funded amount across every document in the packet. Every discrepancy appears in the outline with the exact paragraph and exhibit where each figure appears. It also extracts financial terms, tests the reconciliation provision, and computes the effective APR against the criminal usury threshold.
The Funder Says “Stopped Remitting.” The Record Just Shows Payments Ending.
The complaint alleges your client “intentionally stopped remitting.” The transaction history just ends. No R08 return code, no revocation of authorization, no bank communication. The funder proved cessation, not conduct. But you have to read every line of the payment history to confirm that.
Complaint Allegations Mapped Against What the Exhibits Actually Show
DocketDrafter reads the full transaction history and maps every allegation in the complaint to what the record actually supports. It flags passive-voice allegations without evidence, surfaces line items that undermine the funder's narrative, and identifies guarantor transfers the funder characterized as business revenue.
Motion Types We Support
Every case citation is pre-vetted by attorneys. DocketDrafter does not do research. It applies known-good strategies to new facts.
MSJ Reply Brief
Full reply brief attacking the funder's MSJ. CPLR 4518 foundation defects, cross-document inconsistencies, effective APR computation, and complaint-to-exhibit mapping.
Motion to Vacate Default
Full motion to vacate default judgment with reasonable excuse and meritorious defense frameworks. Affirmation in support with exhibit references for every factual assertion.
Motion to Be Relieved as Counsel
Complete motion package with the required affirmation, proposed order, and proof of service. Handles the procedural requirements so you can move on.
Send me an index number. I'll send you back a full reply brief.
Pick a case where the funder filed an MSJ. I will pull the docket from NYSCEF, upload the MSJ packet along with brief samples from your firm, and run it through DocketDrafter. Within 24 hours, you will have the reply brief as a Word doc.
tommy@docketdrafter.com
Tommy Eberle, DocketDrafter Co-Founder and CEO