How to Write a Legal Complaint in New York

Writing a legal complaint in New York follows a clear, structured sequence to satisfy state pleading rules and keep your story crisp. A complaint is the document that starts a civil case, stating who’s suing whom, why the court has power, the facts, the legal claims, and the relief sought. This guide focuses on filing in the Supreme Court of the State of New York (the trial court), not in small claims. Below, we explain how to write a legal complaint in New York, breaking down each required part and pointing to a sample you can mirror.

1. Choose the Court & Caption it Correctly

Most civil cases start in Supreme Court of the State of New York (that’s the trial court of general jurisdiction). Your caption lists the court, County, case title (Plaintiff v. Defendant), and “Index No.” (eg., “Index No. 755224/2022”). Add a document title on the right, e.g., “Verified Complaint”, and, if you’re serving it with the summons, say so on the summons. Immediately after the caption: the opening identification sentence naming plaintiff and defendants, with parenthetical short-names, ending: “alleges as follows:”

Tip for how to write a legal complaint in New York: keep spacing and colon alignment consistent.

2. Sectioning & Typography Conventions

Common headers include nature of the action, parties, jurisdiction and venue, factual allegations, individual cause of action headings, and prayer for relief. Within factual allegations, use lettered subheadings (A., B., C.) to organize topics. Numbered paragraphs begin at 1 under nature of the action and continue consecutively through the entire pleading. Use “upon information and belief” where a fact is expected to be confirmed in discovery. Each cause of action should open with the incorporation clause: “Plaintiff repeats and realleges the allegations contained in all prior paragraphs as if set forth fully herein.” Maintain readable fonts, standard margins, and single spacing with a blank line between paragraphs for clarity.

3. Nature of the Action

What the action is (e.g., breach of contract, fiduciary duty, etc.). Core transaction/relationship and breach. The relief sought (damages plus injunctive/declaratory).

When learning how to write a legal complaint in New York, remember this is a snapshot, not an argument.

4. Parties and Their Legal Identities

Identify each party’s legal status and locus:

• Entity type and state of formation (LLC, corp., etc.).
• Individual’s residence.
• Where business is conducted in New York (if relevant).

5. Jurisdiction and Venue

Say why a New York court, and this county, is proper. Common bases:

• contractual forum clauses;
• defendants doing business in the county;
• torts occurring in the county;
• CPLR long-arm provisions; GOL § 5-1401/1402 for big-dollar New York–law contracts.

Tip: In commercial cases, track the contract language; in torts, tie the place of injury or conduct to the county. This is core to how to write a legal complaint in New York that survives a motion to dismiss.

6. Factual Allegations

Use global paragraph numbering starting at 1 in Nature and continuing through the entire complaint. Transaction story first (formation, contracts, consideration), then pattern of misconduct (specific episodes), then ongoing threats and repudiation. Keep evidence out; keep ultimate facts in. Use separate paragraphs; group by topic if long.

Mastering this section is central to how to write a legal complaint in New York because it feeds each element of your causes of action.

7. Causes of Action Stated Element by Element

When learning how to write a legal complaint in New York, one of the most critical steps is to break down each cause of action into its essential legal elements. Every claim, whether for negligence, breach of contract, or discrimination, has specific components that must be clearly pleaded and supported by facts. Listing each element and aligning it with factual allegations not only strengthens the complaint but also ensures that the pleading meets the minimum legal standard, which requires statements “sufficiently particular to give the court and parties notice” of the claims.

A well-drafted complaint shows, element by element, how the defendant’s conduct satisfies each required component of the cause of action. For example, in a negligence claim, the complaint should separately address duty, breach, causation, and damages, providing factual support for each. This structured approach not only improves readability but also minimizes the risk of dismissal for failure to state a claim.

8. How to Write a Legal Complaint in New York with a Clear Prayer for Relief

Lettered list stating remedies: declaratory judgment; injunctions specifying prohibited conduct; compensatory & consequential damages; attorneys’ fees; pre/post-judgment interest; and “such other relief as the Court deems just and proper.” Each injunction is precise (e.g., cease providing services/endorsements; cease competing; cease soliciting customers).

9. Signature Block

• Dated line with city/state; “Respectfully submitted,”
• Signature line “/s/ Name,” attorney details (emails, firm, address, phone, fax), “Attorneys for Plaintiff.”
• If verified, add a separate VERIFICATION page: caption, plaintiff/authorized signatory’s sworn statement, notary jurat. (The e-filing “FILED/NYSCEF” footer stamps will appear automatically on the filed PDF; you don’t draft those.)

Sample Verified Complaint

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

––––––––––––––––––––––––––––––––––––––X MAYA R. CHEN, Plaintiff, —against— EVAN J. MORALES, Defendant. ––––––––––––––––––––––––––––––––––––––X

§ § § § § § § §

Index No. 151234/2025 VERIFIED COMPLAINT

Plaintiff, Maya R. Chen (“Plaintiff”), for her Complaint against Defendant Evan J. Morales (“Defendant”), alleges as follows:

NATURE OF THE ACTION

1. This intentional tort action seeks redress for a sustained pattern of coercive, intimidating, and invasive conduct, including offensive touching, physical obstruction of egress in confined spaces, uninvited appearances at Plaintiff’s residence, digital pursuit via alias accounts, and shadowing near Plaintiff’s workplace, occurring in New York County between October 2023 and March 2024; Plaintiff asserts common-law claims for battery, assault, and intentional infliction of emotional distress, and seeks compensatory and punitive damages together with equitable relief to protect her bodily integrity, freedom of movement, and peace of mind.

PARTIES

2. Plaintiff Maya R. Chen is an individual domiciled in New York County, New York.
3. Upon information and belief, Defendant Evan J. Morales is an individual domiciled in New York County, New York.

JURISDICTION AND VENUE

4. This Court has subject matter jurisdiction under the New York Constitution and CPLR § 301.
5. Venue is proper in New York County under CPLR § 503(a) because one or both parties reside in New York County and a substantial part of the events giving rise to the claims occurred here.

FACTUAL ALLEGATIONS

A. Professional Pretext, Boundary Setting, and the November 18, 2023 Meeting

6. In October 2023, Plaintiff met Defendant at a Lower Manhattan networking event; Plaintiff agreed to engage only on a strictly professional basis and in public settings.
7. Between October 25 and November 18, 2023, Defendant pressed for a one-on-one meeting; Plaintiff agreed to a brief public lounge meeting on November 18, 2023, expecting a colleague of Defendant to attend.
8. No colleague appeared; Defendant steered the discussion toward Plaintiff’s living arrangements and routines despite Plaintiff’s redirection to professional topics and her declared 8:30 p.m. departure.
9. Defendant ordered beverages without soliciting Plaintiff’s preference; Plaintiff declined further alcohol, noting morning obligations.
10. Without invitation, Defendant placed his hand on Plaintiff’s thigh under the table; Plaintiff removed his hand, said “No, that is not acceptable,” and stood to leave.
11. As Plaintiff sought to exit, Defendant stepped into the narrow aisle, physically obstructing her egress, insisting she “owed” him five minutes.
12. On the sidewalk, Defendant grasped Plaintiff’s wrist and upper arm to pivot her back toward the entrance; Plaintiff pulled free, departed by rideshare, and later sent a written email-only/work-only boundary notice.

B. Uninvited Residence Appearance and Elevator Blockade

13. On November 20, 2023, Defendant appeared uninvited in Plaintiff’s lobby claiming to return a “left item”; Plaintiff directed him to leave it with the concierge and exit.
14. When Plaintiff turned toward the elevators, Defendant interposed himself between Plaintiff and the open doors, narrowing the space and impeding movement; he left when staff approached.
15. Plaintiff thereafter coordinated visitor screening with building management and purchased a personal alarm and additional door/window sensors.

C. Digital Pursuit, Alias Accounts, and Workplace Shadowing

16. From December 1–8, 2023, Plaintiff received multiple messages from unfamiliar addresses echoing Defendant’s phrasing, demanding a face-to-face meeting.
17. On December 9, 2023, Plaintiff observed Defendant waiting near her office; she avoided contact by entering a store and exiting with coworker escort.
18. Plaintiff’s website logs later showed repeated rapid reloading consistent with monitoring after updates.

D. Escalation Attempts and Public Event Incidents

19. On January 4, 2024, an alias account proposed meeting at Plaintiff’s residence “so no one misreads the vibe”; Plaintiff did not respond and preserved the message.
20. On January 17, 2024, Plaintiff observed Defendant near her building early morning and re-entered to await a private car.
21. On February 2, 2024, at a public review session of her work, Defendant hovered near check-in and maintained line-of-sight; staff escorted Plaintiff out a service exit.
22. On February 14, 2024, an alias email referenced details of Plaintiff’s commute, confirming surveillance; Plaintiff adopted a safety plan with route rotation and check-ins.

E. Entryway Encounter and Continuing Harms

23. On March 5, 2024, Plaintiff saw in the entryway reflection a person matching Defendant’s build pause behind her and turn away when the porter appeared; she reported the incident.
24. Plaintiff has since suffered sleep disruption, hypervigilance, intrusive recollections, avoidance, and work concentration deficits, and incurred therapy costs, security expenditures, and transportation expenses.
25. At all times, Plaintiff withheld consent, set explicit limits, and demanded no further contact; Defendant’s actions were intentional, escalating, and calculated to override Plaintiff’s autonomy and induce fear.

FIRST CAUSE OF ACTION
(Battery)

26. Plaintiff repeats and realleges the allegations contained in all prior paragraphs as if set forth fully herein.
27. Defendant acted with the purpose that bodily contact with Plaintiff occur, or at minimum with substantial certainty that such contact would result. On November 18, 2023, he deliberately placed his hand on Plaintiff’s thigh under the table and, later that evening, intentionally grasped her wrist and upper arm to pivot her toward a lounge entrance despite her express “No.”
28. Defendant’s conduct resulted in direct, non-consensual physical contact with Plaintiff’s person: (a) the under-table placement of his hand on her thigh and (b) the grasping and manipulation of her wrist and upper arm to redirect her body on the sidewalk.
29. The foregoing touchings were of an offensive nature, i.e., offensive to a reasonable sense of personal dignity, particularly after Plaintiff expressly withdrew any purported consent by saying “No.”
30. Plaintiff incurred medical/therapy costs, security purchases, and transportation expenses proximately caused by the battery. Defendant’s conduct was willful, wanton, and malicious, evidencing a conscious disregard for Plaintiff’s bodily integrity. Plaintiff is entitled to compensatory damages for emotional and consequential harms and to punitive damages to punish and deter.

SECOND CAUSE OF ACTION
(Assault)

30. Plaintiff repeats and realleges the allegations contained in all prior paragraphs as if set forth fully herein.
31. Defendant, by deliberately hemming Plaintiff in within a narrow aisle and positioning his body to obstruct her egress, intentionally engaged in conduct designed to compel proximity and confrontation. Defendant further acted intentionally when he placed himself directly in front of Plaintiff’s residential elevator doors to prevent her entry and when he advanced toward Plaintiff outside her workplace following prior incidents, each time closing distance despite Plaintiff’s clear signals to disengage. These purposeful movements were not accidental, incidental, or benign; they were calculated to force an interaction and assert control over space and movement.
32. Defendant’s physical placement of his body in close quarters, cornering Plaintiff in the aisle and physically blocking the elevator doors, created a present and immediate risk of unwanted touching. His forward-advancing steps toward Plaintiff outside her workplace, taken after prior unpermitted contacts, conveyed an imminent threat that he would again lay hands on her if she did not submit to his demands for conversation and proximity. The proximity, blocking, and advancing gestures were of such a nature that a reasonable person in Plaintiff’s position would perceive an immediate prospect of harmful or offensive contact.
33. Plaintiff suffered anxiety, sleep disturbance, and hypervigilance, impairing work concentration and social functioning. Plaintiff incurred economic losses associated with safety measures reasonably undertaken in response to the assaults. Defendant’s conduct was in reckless or knowing disregard of Plaintiff’s rights.

THIRD CAUSE OF ACTION
(Infliction of Emotional Distress)

33. Plaintiff repeats and realleges the allegations contained in all prior paragraphs as if set forth fully herein.
34. Defendant engaged in a sustained and escalating pattern that exceeds all bounds of decency and is utterly intolerable in a civilized community, including: uninvited appearances at Plaintiff’s residence; physically obstructing Plaintiff in confined spaces; alias-based digital pursuit to evade blocks; shadowing Plaintiff at her workplace; and pressing for in-home meetings after explicit refusals. Taken together and in context, these acts served no legitimate purpose and were calculated to strip Plaintiff of autonomy and safety.
35. Defendant acted with the purpose of intimidating and pressuring Plaintiff or, at minimum, in reckless disregard of the substantial probability that his conduct would cause severe emotional distress. He persisted after clear “No”s, reinitiated contact through evasive methods, and targeted sensitive locations (home and workplace), demonstrating knowledge that his conduct would foreseeably inflict serious emotional harm.
36. Defendant’s extreme and outrageous conduct was a direct and proximate cause of Plaintiff’s injuries. The temporal sequence between Defendant’s residential intrusions, workplace shadowing, and digital circumvention and the onset and exacerbation of Plaintiff’s symptoms, together with the protective measures Plaintiff undertook (enhanced security, transportation changes, therapy), establishes that Defendant’s actions precipitated and perpetuated Plaintiff’s distress.
37. As a result, Plaintiff suffered severe emotional distress, including panic-like episodes, insomnia, intrusive recollections, hypervigilance, and pervasive avoidance behaviors, that materially impaired daily functioning and required professional intervention. Defendant’s misconduct was willful, wanton, and malicious, warranting punitive damages.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Maya R. Chen respectfully demands judgment against Defendant Evan J. Morales as follows:

1. Compensatory damages on all causes of action in an amount to be determined at trial, including damages for emotional distress, humiliation, loss of enjoyment of life, and related harms;
2. Special and consequential damages, including therapy and mental-health treatment costs, security equipment and services, transportation and safety-related expenses, and other reasonably foreseeable out-of-pocket losses;
3. Punitive damages on the intentional tort claims, in an amount sufficient to punish and deter;
4. Declaratory relief adjudging that Defendant’s conduct violated Plaintiff’s common-law rights to bodily integrity, freedom of movement, and freedom from outrageous harassment;
5. Injunctive relief as the Court deems appropriate, including prohibiting Defendant from contacting Plaintiff directly or indirectly; from approaching within a Court-determined distance of Plaintiff’s person, residence, workplace, or regular routes; and from surveilling or monitoring Plaintiff’s online professional profiles or physical movements;
6. Pre-judgment and post-judgment interest as permitted by law;
7. Costs and disbursements of this action, including reasonable expert fees; and
8. Such other, further, and different legal and equitable relief as the Court deems just and proper.

Dated: September 24, 2025
New York, New York

Respectfully submitted,

/s/ Alicia M. Torres
Alicia M. Torres
atorres@torresfeldman.com
Benjamin R. Feldman
TORRES & FELDMAN LLP
570 Lexington Avenue, Fl. 24
New York, NY 10022
Tel: (212) 555-0147
Fax: (212) 555-0189
Attorneys for Plaintiff

ATTORNEY VERIFICATION

I, ALICIA M. TORRES, ESQ., an attorney duly admitted to practice before the Courts of the State of New York, and a member of Torres & Feldman LLP, attorneys for Plaintiff in the within action, hereby affirms under penalty of perjury:

I have read the foregoing Amended Verified Complaint and know the contents thereof; the same is true to my own knowledge, except as to the matters therein stated to be alleged on information and belief, and as to those matters I believe them to be true. The sources of my information and belief are conversations with Plaintiff, review of contemporaneous communications and building/security correspondence, and my firm’s investigation. The reason this verification is made by me and not by Plaintiff is that Plaintiff is not presently within the county where I maintain my office.

Dated: September 24, 2025
New York, New York 

/s/ Alicia M. Torres
Alicia M. Torres