Spot-Check Every Citation in a Brief Before Filing

The task

You're a litigator or paralegal doing a last pass on a brief before it goes out the door. Every case cite, statute pin, and quoted passage needs to actually exist and say what the brief claims it says — post-Mata v. Avianca, this is table stakes, not paranoia. This workflow triages which cites need the hardest look, so you spend your Westlaw or Lexis time where it matters.

Before AI

You (or a junior) scroll the brief, highlight every citation, dump them into a checklist, then pull each one up in Westlaw or Lexis and verify: does the case exist, is the reporter cite right, does the pin actually support the proposition, is it still good law. On a 25-page brief with 40 cites, that's a solid half-day. Most cites are fine; the point is finding the two that aren't.

The workflow

The idea: use the model to extract and triage, not to verify. LLMs hallucinate cites — they cannot be trusted to confirm one exists. But they're very good at pulling every citation out of prose and flagging which claims are load-bearing.

1. Extract every citation into a clean table

Paste the brief text into this prompt. It pulls out cites and the proposition each one supports, so you have a working checklist.

You are a paralegal preparing a citation-check worksheet. Below is the text of a legal brief. Do the following:

1. Extract EVERY citation in the brief. Include case cites (with reporter and pin), statutes, regulations, rules, and any quoted material attributed to a source.
2. For each citation, capture the exact sentence(s) in the brief that use it — this is the "proposition" the citation supports.
3. Output a markdown table with columns: # | Citation (as written) | Type (case/statute/rule/quote/other) | Proposition (verbatim from brief, trimmed to one sentence) | Page/section where it appears.
4. Do NOT verify whether the citation is real or accurate. Do NOT add cites that aren't in the text. Just extract what's there.

Brief text follows below the line.
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BRIEF IN OPPOSITION TO DEFENDANT'S MOTION TO DISMISS — Hartwell Logistics LLC v. Corvin Freight Systems Inc., No. 25-cv-04182 (N.D. Cal.)

I. INTRODUCTION
Defendant Corvin Freight asks this Court to dismiss Plaintiff Hartwell's breach of contract and promissory estoppel claims on the pleadings. The motion fails at the threshold. Under Rule 12(b)(6), the Court must accept all well-pleaded allegations as true and draw all reasonable inferences in Plaintiff's favor. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Dismissal is appropriate only where the complaint fails to state a claim that is "plausible on its face." Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007).

II. ARGUMENT
A. Plaintiff has adequately pleaded breach of the Master Services Agreement.
California law requires only that a plaintiff plead (1) a contract, (2) plaintiff's performance, (3) defendant's breach, and (4) resulting damages. Oasis West Realty, LLC v. Goldman, 51 Cal. 4th 811, 821 (2011). The Complaint alleges each element with particularity. See Compl. ¶¶ 22–41. Defendant's argument that the MSA's integration clause bars Plaintiff's claims misreads the contract; an integration clause does not preclude claims arising from the four corners of the agreement itself. Grey v. American Management Services, 204 Cal. App. 4th 803, 807 (2012).

B. The promissory estoppel claim survives independently.
Promissory estoppel is available where a promise is "clear and unambiguous in its terms." Aceves v. U.S. Bank, N.A., 192 Cal. App. 4th 218, 225 (2011). Defendant's May 14, 2024 email to Plaintiff's CFO — stating "we will honor the extended rate through Q4 regardless of volume" — meets that bar. Compl. ¶ 34. The Ninth Circuit has held that email correspondence can constitute an enforceable promise where the language is sufficiently definite. Sateriale v. R.J. Reynolds Tobacco Co., 697 F.3d 777, 790 (9th Cir. 2012).

C. Defendant's statute of frauds defense is premature.
The statute of frauds is an affirmative defense that generally cannot be resolved on a 12(b)(6) motion. Cal. Civ. Code § 1624; see also Rutherford Holdings, LLC v. Plaza Del Rey, 223 Cal. App. 4th 221, 228 (2014). Even if reached, the doctrine of part performance removes the bar where, as here, Plaintiff has rendered services in reliance on the promise. Sutton v. Warner, 12 Cal. App. 4th 415, 422 (1993).

III. CONCLUSION
For the foregoing reasons, Defendant's motion should be denied in its entirety.

2. Triage the list by verification risk

Not every cite carries the same weight. Some are boilerplate (Iqbal, Twombly) — a real case, but if you botched the pin the sky won't fall. Others are load-bearing — the one case doing all the work in a section. This prompt separates them.

Using the citation table from the previous step, add three columns and re-output the table:

- "Load-bearing?" — YES if the argument in that section collapses without this cite; NO if it's boilerplate/general standard/string cite support.
- "Verification priority" — HIGH / MEDIUM / LOW based on: load-bearing status, whether a specific pin cite is used, and whether the cite supports a direct quotation.
- "What to check on Westlaw/Lexis" — a one-line instruction, e.g., "Confirm 51 Cal. 4th 811 pin at 821 states the four elements as listed" or "Confirm quoted language appears at 225."

Rules:
- Direct quotations always get HIGH priority — a misquote is a sanctionable error.
- Cites to broad standards (Iqbal, Twombly, Rule 12(b)(6)) are usually LOW unless a specific pin is doing work.
- A cite that appears exactly once and carries an entire subsection's argument is load-bearing.

Output the full table. Then below the table, list the HIGH priority items again as a numbered checklist for the reviewer.

3. Draft the reviewer's memo

Now flip the output into something you'd hand to a junior or use yourself at the terminal.

Based on the triaged table, write a short reviewer's memo (under 250 words) titled "Pre-filing citation check — priorities." It should:

1. State the total number of citations extracted and the count at each priority level.
2. List the HIGH-priority items with one line each explaining the specific risk (quote accuracy, load-bearing proposition, unusual pin, etc.).
3. Flag any citation where the brief's proposition seems to reach beyond what a case of that vintage/court would typically hold — do NOT claim the cite is wrong; just note "worth reading the holding carefully, not just the headnote." Be conservative here; only flag if something genuinely reads oddly.
4. End with a one-line reminder that this memo does NOT verify existence or accuracy of any cite — that requires pulling each source in Westlaw or Lexis.

Plain prose. No table. No emoji. No hedging language beyond what's specified.

Gotchas

• The model cannot verify cites exist. This is the whole point. It has no live database access, and even if it did, its training data is stale. Anything that looks like "confirmed good law" from the model is a hallucination waiting to happen. Use the output as a worklist, not an answer.
• Pasted text loses formatting. If your brief has footnoted citations, paste with footnotes inline or the extractor will miss them. Do a Ctrl-F for "see" and "cf." in the original to sanity-check the count.
• String cites get collapsed. Long strings ("see X; see also Y; accord Z") sometimes come out as one row. Skim the extracted table against the brief before triaging.
• Quoted language is where you get sanctioned. The ABA guidance following the *Mata v. Avianca* fallout is blunt about verification duties. If the brief has a direct quote, pull the source and eyeball the quote character-for-character. No exceptions.
• Don't paste privileged or sealed material into a consumer chatbot. Use your firm's enterprise instance with a zero-retention agreement, or redact party names first. The workflow works fine on anonymized text.

Time saved

Manual extract-and-checklist on a 30-40 cite brief runs 45-90 minutes before you even open Westlaw. The extraction and triage steps compress that to about 5-10 minutes of paste-and-review, leaving your billable time for the part that actually requires a lawyer: pulling each HIGH-priority cite and reading the pin. Conservative estimate — depends heavily on brief length and how clean the source formatting is.

What we got when we ran it

We executed every prompt above, in order, against the sample input (model: claude-sonnet-4-6). Outputs below are real and unedited apart from length truncation.

Step 1 output

# Citation-Check Worksheet Matter: Hartwell Logistics LLC v. Corvin Freight Systems Inc., No. 25-cv-04182 (N.D. Cal.) | # | Citation (as written) | Type | Proposition (verbatim from brief, trimmed to one sentence) | Page/Section | |---|---|---|---|---| | 1 | Rule 12(b)(6) | Rule | Under Rule 12(b)(6), the Court must accept all well-pleaded allegations as true and draw all reasonable inferences in Plaintiff's favor. | § I (Introduction) | | 2 | Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) | Case | Under Rule 12(b)(6), the Court must accept all well-pleaded allegations as true and draw all reasonable inferences in Plaintiff's favor. | § I (Introduction) | | 3 | Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) | Case | Dismissal is appropriate only where the complaint fails to state a claim that is "plausible on its face." | § I (Introduction) | | 4 | "plausible on its face" | Quote | Dismissal is appropriate only where the complaint fails to state a claim that is "plausible on its face." | § I (Introduction) | | 5 | Oasis West Realty, LLC v. Goldman, 51 Cal. 4th 811, 821 (2011) | Case | California law requires only that a plaintiff plead (1) a contract, (2) plaintiff's performance, (3) defendant's breach, and (4) resulting damages. | § II.A | | 6 | Compl. ¶¶ 22–41 | Other (pleading ref.) | The Complaint alleges each element with particularity. | § II.A | | 7 | Grey

…output truncated at 250 words.

Step 2 output

# Citation-Check Worksheet — Enhanced Matter: Hartwell Logistics LLC v. Corvin Freight Systems Inc., No. 25-cv-04182 (N.D. Cal.) | # | Citation (as written) | Type | Proposition (verbatim from brief, trimmed to one sentence) | Page/Section | Load-bearing? | Verification Priority | What to Check on Westlaw/Lexis | |---|---|---|---|---|---|---|---| | 1 | Rule 12(b)(6) | Rule | Under Rule 12(b)(6), the Court must accept all well-pleaded allegations as true and draw all reasonable inferences in Plaintiff's favor. | § I (Introduction) | NO | LOW | Confirm FRCP 12(b)(6) is the correct rule for failure-to-state-a-claim dismissal standard. | | 2 | Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) | Case | Under Rule 12(b)(6), the Court must accept all well-pleaded allegations as true and draw all reasonable inferences in Plaintiff's favor. | § I (Introduction) | NO | LOW | Confirm pin 678 addresses the accept-as-true/reasonable-inference standard (note: 678 is more commonly the "plausibility" passage — verify the accept-as-true language sits there and not at a different pin). | | 3 | Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) | Case | Dismissal is appropriate only where the complaint fails to state a claim that is "plausible on its face." | § I (Introduction) | NO | MEDIUM | Confirm "plausible on its face" quoted language appears at pin 570 and not elsewhere in the opinion. | | 4 | "plausible on its face" | Quote | Dismissal is appropriate only where the complaint fails

…output truncated at 250 words.

Step 3 output

Pre-filing Citation Check — Priorities Hartwell Logistics LLC v. Corvin Freight Systems Inc., No. 25-cv-04182 (N.D. Cal.) Fifteen citations were extracted from the brief: nine rated HIGH priority, three MEDIUM, and three LOW. HIGH-priority items requiring review before filing: Twombly pin 570 / "plausible on its face" (#3, #4): Both Twombly and Iqbal use this phrase; confirm the pin and the attribution are internally consistent across the brief. Oasis West Realty (#5): Load-bearing for the entire breach-of-contract subsection; confirm pin 821 recites the four elements in the sequence stated and pull negative history. Grey v. American Management Services (#7): Sole authority for the integration-clause argument; confirm pin 807 supports the precise proposition as framed and run negative treatment. Aceves / "clear and unambiguous in its terms" (#8, #9): Direct quotation tied to a specific pin; confirm word-for-word accuracy — the actual text may read "definite and unambiguous" or similar. Email quotation / Compl. ¶ 34 (#11): Reconcile the quoted language against both the filed complaint and the underlying email document before filing. Sateriale (#12): Worth reading the holding carefully, not just the headnote — the case arose in a consumer-promotion context, and the breadth of the proposition as applied to a commercial freight email may warrant closer examination. Rutherford Holdings (#14) and Sutton v. Warner (#15): Both are load-bearing for the statute-of-frauds subsection; confirm pins and good-law status. This memo does not verify the existence or accuracy of any citation — that requires pulling each source directly in Westlaw or

…output truncated at 250 words.

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This content is for informational purposes only and is not legal advice. Confirm confidentiality, privilege, and jurisdictional rules before using any AI tool with client matters.