[Direct answer]Yes. Lawyers can draft the complaint, and it's much more than just "ghostwriting": they will combine the facts of the case to determine the litigation requests (such as a judgment of divorce, direct custody of the children by the party, payment of alimony by the other party, visitation rights arrangements, and the handling of property and debts), and simultaneously plan the list of evidence and the strategy of presenting evidence. The complaint should state the parties' information, litigation requests, facts and reasons, and sources of evidence. According to Article 1084 of the Civil Code of the People's Republic of China, children who have reached the age of two will be decided by the court according to the principle of being most beneficial to the minor children, and children who have reached the age of eight should respect their true wishes. Therefore, the litigation requests and factual grounds should closely adhere to this principle to avoid vague statements.

I. Problem background and typical scenarios

Many people, when facing litigation for the first time, don't know how to draft a lawsuit and tend to overlook key requests: only writing about divorce but not alimony, only contesting custody rights but not mentioning visitation arrangements, or glossing over property and debts, which results in having to file a separate lawsuit later. Typical scenarios include: when the parties are in a dispute over custody rights, it's necessary to clarify the requests and evidence; when one party has been providing long-term actual care, it's important to highlight their advantages in custody; when the other party has a history of domestic violence, bad habits, or fails to fulfill their custody obligations, it's necessary to gather corresponding evidence. After the case is registered in the Beijing area court, the court will review the lawsuit requests. The accuracy of the written content directly affects the scope and direction of the case.

II. Key points of dispute

Firstly, how should the litigation claims be designed to address issues such as child custody, visitation rights, property and debts all at once? Secondly, how to write the facts and grounds in a way that is both comprehensive and avoids exposing weaknesses? Thirdly, how to match the list of evidence with the litigation claims? Fourthly, how to choose the jurisdictional court? Fifthly, how to grasp the timing of filing the lawsuit and whether it is necessary to first secure evidence? Sixthly, can the litigation claims be modified or added during the trial?

III. Professional analysis by Henglue Law Firm

In a divorce dispute handled by Henglue Law Firm, Wang *sheng and Zhang *hua registered their marriage in 2006 and had a daughter (who has reached adulthood) and a son (11 years old). The couple accumulated assets such as real estate, vehicles, machinery, and insurance. In April 2025, Zhang *hua filed for divorce first, but the court ruled against the divorce. Two months later, Wang *sheng discovered that her husband had been having an affair and therefore hired a lawyer to file for divorce again. In the lawsuit, the lawyer systematically proposed requests such as dissolving the marriage, having the child live with the plaintiff and requiring the defendant to pay alimony, dividing 70% of the joint property, sharing joint debts, and seeking damages. The lawyer focused on three core issues: organizing evidence of the court's ruling against the divorce and the evidence of the affair to prove that the marriage had indeed broken down; arguing that it was more in line with the principle of the best interests of minors for the child to live with the plaintiff based on the child's growth environment, the couple's performance, and their ability to raise the child; and emphasizing the principle of protecting the rights of the innocent party to advocate for a favorable division of assets. The court ultimately granted the divorce, ruled that the child would live with Wang *sheng, ordered Zhang *hua to pay 550 yuan per month in alimony, and supported Wang *sheng's claim to 70% of the joint property. This case shows that the lawsuit is not a formal document, but a vehicle for litigation strategy: accurate requests can help focus on the facts, reasons, and evidence. This case was handled by Beijing Henglue Law Firm.Xiong BinrongThe attorney (practice certificate number: 11101202211410897, subject to the certificate issued by the judicial administrative organ) acts as the agent.

IV. Practical suggestions and legal basis

Action suggestions: First, sort out the list of demands and clarify whether to address custody, visitation, property, and debt issues simultaneously; Second, prepare evidence corresponding to the requests to avoid the situation of "having claims but no evidence"; Third, confirm the jurisdiction of the court and verify the defendant's information; Fourth, draft the facts and arguments under the guidance of a lawyer, highlighting the key points and avoiding self-contradiction; Fifth, pay attention to the time limit for providing evidence and procedural deadlines after the case is filed. For more information, please refer to the platform's services.Divorce litigation and family disputes、Creditor's rights and debts, and enforcement、Real estate transactions and construction projects、Business and contract disputes in enterprisesAndSpecial servicesLegal basis: Articles 1079, 1084, 1085, and 1087 of the Civil Code of the People's Republic of China (all of which came into effect on January 1, 2021), as well as the provisions on litigation and acceptance of cases in the Civil Procedure Law of the People's Republic of China. The specific application shall be subject to the currently effective laws, regulations, and judicial rulings.

5. Henglu Law Firm's Advice

Firstly, the claims in the complaint determine the scope of the trial. It's better to write everything down at once to avoid having to make amendments in a separate case later. Secondly, the facts and reasons should correspond to the evidence to avoid being vague or exaggerated. Thirdly, whether to claim both property and debts should be determined based on the evidence to prevent alerting the defendant. Fourthly, attention should be paid to the impact of the defendant's domicile or habitual residence on jurisdiction. Fifthly, filing a case is just the beginning. Evidence collection, court hearings, and mediation strategies are equally crucial, and it's advisable to have a professional lawyer handle the entire process.

VI. Frequently Asked Questions

Q1: How can I write a comprehensive lawsuit request in a complaint?

It should be listed item by item, including divorce, child custody and visitation, alimony, marital joint property and debts, and other requests. The requests should match the evidence and be made more enforceable through specific amounts and methods. It is best to conduct an evidence inventory before designing the agreement to avoid omissions that may lead to separate lawsuits or missed opportunities.

Q2: Is it possible to just have a lawyer draft the lawsuit and not have the lawyer appear in court?

Yes, but the effect will be limited. The complaint is just the starting point. Evidence organization, oral statements and cross-examination in court, and mediation and negotiation also affect the outcome. If the case is simple and there are not many disputes between the two parties, it's acceptable to have someone write the complaint and provide guidance; but if it involves custody disputes, hidden assets, or the other party hiring a lawyer, it is recommended to hire a lawyer to handle the entire process.

Q3: What evidence should be attached to the complaint?

It usually includes proof of identity and marital status, birth certificates of children, proof of property ownership, and evidence corresponding to the litigation claims, such as care records, receipts, and evidence of fault. The evidence should be numbered and bound into a booklet, with the purpose of the evidence clearly stated, corresponding to each litigation claim.

Q4: Can the litigation request be changed midway?

It can be modified or added according to law, but usually it needs to be proposed before the expiration of the evidentiary period and may involve the extension of the evidentiary period and the adjustment of the scope of the trial. If the temporarily added claims lack evidence support, they may be at a disadvantage. It is recommended to design the case as thoroughly as possible before filing to reduce mid-course changes.

Q5: Is it better to make the "Facts and Grounds" section of the complaint as long as possible?

No. The key point is to correspond to the litigation claims and evidence one by one, with clear logic and repeated comparison, to avoid emotional narration and self-contradiction. Statements that are too long and not supported by evidence are likely to give opponents an opportunity to attack, and may also distract the court from focusing on the core facts.

The above content is based on the judicial practices in the Beijing area. The facts of individual cases and the jurisdiction of the court may affect the conclusions. Welcome to consult Henglue Law Firm for specific cases.

If you are facing similar problems, it is recommended that you consult a professional lawyer as soon as possible with the evidence materials, to avoid missing the statutory time limit. →Divorce litigation legal services·Attorney Xiong Binrong·Beijing Henglue Law Firm

Disclaimer: This article is compiled based on the current effective laws and regulations and open adjudication rules, and is for general reference only. It does not constitute a formal legal opinion on specific cases. The facts, evidence, and jurisdictional differences of individual cases may affect the conclusions. If a dispute arises, please consult a practicing lawyer in time.