Syncora Connect/Playbooks/Litigation Matrix

Litigation matrix

A systems-engineering view of the case. Every claim breaks into legal elements. Every element is backed by evidence and court documents. Empty cells are the gaps to close before trial.

Overall readiness

50%

Case nameCase numberForumTrial date

← Phase playbook

Count I — Breach of Contract

N.Y. common law — breach of written contract · plaintiff

Provable, work to do

67%

Element to prove	Burden	Strength	Evidence notes	Documents	Case law
Existence of a valid contract			Signed MSA with integration clause.	Dkt. 1Ex. A
Plaintiff's performance			Delivery logs and acceptance emails.	Ex. A
Defendant's breach			CFO admits withholding payment in Q3.	Reyes Depo 88:2 – 92:15
Damages caused by the breach			Need expert report to quantify lost profits.

Count II — Fraudulent Inducement

N.Y. common law fraud · plaintiff

Gaps remain

33%

Element to prove	Burden	Strength	Evidence notes	Documents	Case law
Material misrepresentation			Pre-contract emails — need to authenticate.
Scienter (knowledge of falsity)			No direct evidence yet; pursue in 30(b)(6).
Justifiable reliance			Client decision memo references the rep.
Resulting damages			Overlap with Count I damages model.