--- name: co-fact-check description: > This skill should be used to fact-check a Colorado court filing before it is filed. Triggers include "fact-check this Colorado filing", "verify citations in my motion", "check the rule citations in this brief", "check Colorado statute citations", "audit this Colorado pleading", "review my pro se filing before I file it", "check that my numbers are consistent across the packet". Runs four passes: (1) citation verification against canonical sources; (2) internal consistency within a single document (dates, dollar amounts, defined terms); (3) packet consistency across motion + declaration + proposed order + certificate of service; (4) sworn- versus-argued consistency between declaration assertions and motion arguments. version: 0.1.0 --- # Fact-Check Colorado Court Filings > **NOT LEGAL ADVICE.** Fact-checking detects errors but does not > assess legal sufficiency. Verify substantive law independently. Use this skill before any Colorado court filing leaves the desk. It runs four passes: ## Pass 1 — Citation verification For every rule, statute, regulation, and case citation in the document, verify: - **Rule cited**: exists and says what the brief claims. Use the current C.R.C.P. (Colorado Judicial Branch), CRE, or C.A.R. text. - **Statute cited**: exists at the cited subsection. Pull from https://leg.colorado.gov/colorado-revised-statutes. - **Federal statute cited**: exists at the cited subsection. Pull from https://uscode.house.gov. - **Regulation cited**: exists at the cited C.F.R. section. Pull from https://ecfr.gov. - **Case cited**: exists; the parallel citation is correct; the proposition stands for what the brief claims; the case has not been overruled or distinguished by more recent authority. ### Colorado citation format checks Per `co-statewide-format` and `co-law-references`: - Colorado Supreme Court (post-2012): `[Party A] v. [Party B], [YEAR] CO [###], ¶ [#], [###] P.3d [###]` - Colorado Court of Appeals (post-2012): `[Party A] v. [Party B], [YEAR] COA [###], ¶ [#], [###] P.3d [###]` - Colorado pre-2012: `[Party A] v. [Party B], [###] P.[#d] [###] (Colo. [YEAR])` or `(Colo. App. [YEAR])` - Colorado statutes: `C.R.S. § XX-XX-XXX` (always with `§`) - C.R.C.P.: `C.R.C.P. XX(x)(x)` (no `§` for rules) - CRE: `C.R.E. XXX` (use periods) - Federal statutes: `XX U.S.C. § XXXX` - C.F.R.: `XX C.F.R. § XXXX.XX` Common errors: - Missing `§` on a Colorado statute citation - Using a `§` on a C.R.C.P. citation (no `§` for rules) - Citing pre-2012 Colorado cases with neutral-citation format (only post-2012 cases have `[YEAR] CO [###]`) - Citing to P.3d page when the case has both neutral and parallel — use both, paragraph-anchored - Missing the `(Colo. App. YEAR)` jurisdiction tag on pre-2012 COA cases ## Pass 2 — Internal consistency Within a single document, verify: - **Dates**: every date stated in the document is consistent with every other appearance of that date (date of service, date of contract, date of last payment, date of the loan, etc.) - **Dollar amounts**: every dollar amount is consistent and totals add up (principal + interest + fees + costs = total demanded) - **Defined terms**: any term defined with `(the "Account")` etc. is used consistently throughout (no slipping into "the loan" or "the debt" once defined as "the Account") - **Party names**: each party named consistently (no switching between "Plaintiff", "Plaintiff Smith", and "Smith") - **Cross-references**: every "see paragraph X" or "see Exhibit Y" actually exists at the cited location - **Numbered paragraphs**: sequential without gaps or duplicates ## Pass 3 — Packet consistency Across the multi-document filing packet (motion + declaration + proposed order + certificate of service): - **Caption identical** in every document: court name, case number, party names, division, courtroom must match exactly - **Document title** matches in the motion's certificate of service and the proposed order's title bar - **Dates** align: the certificate of service date should match the signature date on the motion; the declaration's "executed on" date should align with when the declaration was signed - **Relief sought** matches: the motion's prayer ("WHEREFORE, the Court is respectfully requested to ____") must mirror the proposed order's ordering language ("IT IS HEREBY ORDERED that ____") - **Exhibits** referenced in the motion are described in the declaration's exhibit list and physically attached - **Conferral status** in the certificate of conferral is consistent with any narrative description of conferral attempts in the motion body - **Page counts** comply with C.R.C.P. 121 § 1-15 limits (15 pages motion/response; 10 pages reply) — flag anything over the limit before filing ## Pass 4 — Sworn vs. argued Compare what is sworn-to in the supporting declaration / affidavit against what is argued in the motion or brief: - Every **factual assertion** in the motion's argument section should be either (a) supported by a citation to a paragraph of the declaration, (b) admitted in the pleadings, or (c) a matter of judicial notice - Identify any factual claim in the motion that is **not** supported by the declaration — that's a gap to fix before filing - Identify any factual claim in the declaration that is **not used** in the motion — consider whether it belongs in the declaration at all - Verify the declaration's **personal-knowledge foundation** — declarations under C.R.S. § 13-27-104 must be based on personal knowledge; flag any paragraph that begins "I believe" or "I understand" without a foundational basis ## Output format When invoked on a packet, produce a structured report: ``` FACT-CHECK REPORT — [Document title / Case number] Pass 1 (Citations) PASS C.R.C.P. 12(b)(5) — exists; correct subsection WARN C.R.S. § 13-80-103.5 — verify (1)(a) vs (1)(j) FAIL Smith v. Jones, 2019 COA 45 — no such case found at this cite; check year (perhaps 2017 COA 45?) Pass 2 (Internal consistency) PASS Defined terms used consistently WARN Paragraph numbering jumps from 6 to 8 Pass 3 (Packet consistency) PASS Caption matches across motion, declaration, proposed order FAIL Motion seeks $4,500 in fees; Proposed Order awards $4,000 Pass 4 (Sworn vs. argued) FAIL Motion ¶ 3 asserts "Plaintiff sent a 30-day notice"; no corresponding declaration paragraph Summary: 8 PASS / 3 WARN / 3 FAIL — DO NOT FILE until 3 FAILs resolved. ``` ## Composition - For statewide format checks: `co-statewide-format` + `scripts/format-check.py` on the generated `.docx` - For deadline arithmetic checks: `co-deadlines` - For pre-filing QC: `co-quality-check` (this skill is the deeper evidentiary-citation pass; `co-quality-check` is the lighter format-and-content pass) ## References - `references/citation-checklist.md` — Colorado citation conventions with common errors - `references/cross-document-checks.md` — packet-consistency checklist - `references/sworn-vs-argued.md` — declaration-to-motion mapping technique