---
title: "Draft urgent freezing, recovery or injunction papers from the facts brief"
url: "https://ailawframework.com/practice/family-law/draft-urgent-freezing-recovery-or-injunction-papers-from-the-facts-brief"
type: "task"
site: "AI Law Framework"
id: "A16-T1-R9"
practice_area: "Family Law"
tier: "red"
lawyer_review: "required"
last_reviewed: "2026-10-22"
---

# Draft urgent freezing, recovery or injunction papers from the facts brief

> The affidavit is barred to the tool: the lawyer drafts it, and the application and proposed orders as well.…

Canonical page: https://ailawframework.com/practice/family-law/draft-urgent-freezing-recovery-or-injunction-papers-from-the-facts-brief  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Family Law](https://ailawframework.com/practice/family-law.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| How AI is used | The affidavit is barred to the tool: the lawyer drafts it, and the application and proposed orders as well. Index the annexures against the lawyer's draft in both directions, listing every annexure the draft does not refer to and every document the draft refers to that is not annexed. List every asserted fact anywhere in the draft that has no source in the facts brief or the documents — asset dissipation, travel and a child's whereabouts are examples, not the limit. Check the lawyer's draft affidavit against every disclosure item the court's without-notice rule requires and list the ones not yet addressed — previous proceedings, orders in force, any breach of an order, any allegation of family violence or child abuse, hardship or prejudice to the respondent, a child or a third party, whether the respondent or their lawyer has been told, the applicant's capacity to give an undertaking as to damages, why the order must be made urgently, and the other party's last known address. List every relief sought in the application with no matching proposed order, and every order sought that no paragraph of the affidavit supports. Flag departures from the court's urgent-list and without-notice filing requirements. Whether the duty of full and frank disclosure is met is the lawyer's judgment, not a form the tool can check. |
| What the lawyer must review | The lawyer drafts the affidavit, the application and the orders, and the deponent must adopt the evidence. Full and frank disclosure on a without-notice application sits with the lawyer: read the draft against the source documents for adverse facts, and satisfy yourself the sworn material covers every matter the without-notice rule enumerates, including the applicant's capacity to give an undertaking as to damages. Check the court's current urgent-list and without-notice rules, and confirm each order sought is one the court can make. |
| Written for / versions | 1 jurisdiction versions below |

## Checking plan

**Line-by-line review**

Review the complete output at the level of each line, paragraph or clause; check facts, meaning and omissions.

- What the AI does: Organise the evidence and authorities for urgent review; time pressure does not remove verification.
- What the lawyer does: Set the scope, verify the evidence, resolve exceptions and approve the final output for its intended use.
- Who reviews: Responsible lawyer with competence in the matter
- Basis: Suggested checking approach based on the task guidance. Complete the assessment for the actual tool, information and jurisdiction.
- Why: The plan reflects the described work and review requirements. Policy colours are not used to determine permission or checking.
- Written for: AU

## Checks the lawyer makes

1. Confirm each material factual assertion directly with the client and source record.
2. Review existing orders, safety issues and any relevant contrary material.
3. Check the applicable test, procedure, service position and required evidence.
4. Verify every authority and statement in the proposed filing.
5. Record the responsible lawyer’s approval of the exact documents before filing.

## Notes

- Confirm the required checking with the responsible lawyer before work starts. The checking approach does not establish permission to use AI.

## Sources

- [Federal Circuit and Family Court of Australia — AI practice direction](https://www.fcfcoa.gov.au/pd/pd-ai) (checked 2026-09-16)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Application – enforcement (family law, other than parenting)](https://ailawframework.com/precedents/family-law/form-fcfcoa-application-enforcement.md) | Form | Yellow | Link to the family law Application – Enforcement, used to enforce existing orders other than parenting orders, with an affidavit and a copy of the orders. |

Signed-in accounts can read the full text of each one.

## Jurisdiction versions

| Jurisdiction | Level |
| --- | --- |
| [United States](https://ailawframework.com/practice/family-law/draft-urgent-freezing-recovery-or-injunction-papers-from-the-facts-brief/united-states.md) | Red |

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*