Dear Customer, the way to do this is that with every count (You should have a heading such as "COUNT 2" return "VEXATIOUS LITIGATION" return (22 the number will be the next paragraph number in your complaint - every paragraph will have a number) : "This Count incorporates each and every fact and allegation as set forth above, as if set forth herein in full"
My practice book says to start each count anew, with No. 1.
Ok. I see what you've said. I'll put that language under each new Count, yes..
"This Count incorporates each..."
Correct. Some attorneys like to be very specific: This count incorporates Paragraph 1 - 21 as if set forth ...
I can be specific.
Another way to do it (one that I prefer as it avoids problems during revisions, but may have some procedural weaknesses that most judges overlook): an opening paragraph: Each and every paragraph, fact and allegation, shall be included and incorporated in each allegation as if set forth therein.
Do I follow this after the "Facts" and the "Introduction" too.
Thanks very much. I'm gonna rate you now.... :)
DISCLAIMER: Answers from Experts on JustAnswer are not substitutes for the advice of an attorney. JustAnswer is a public forum and questions and responses are not private or confidential or protected by the attorney-client privilege. The Expert above is not your attorney, and the response above is not legal advice. You should not read this response to propose specific action or address specific circumstances, but only to give you a sense of general principles of law that might affect the situation you describe. Application of these general principles to particular circumstances must be done by a lawyer who has spoken with you in confidence, learned all relevant information, and explored various options. Before acting on these general principles, you should hire a lawyer licensed to practice law in the jurisdiction to which your question pertains.
The responses above are from individual Experts, not JustAnswer. The site and services are provided “as is”. To view the verified credential of an Expert, click on the “Verified” symbol in the Expert’s profile. This site is not for emergency questions which should be directed immediately by telephone or in-person to qualified professionals. Please carefully read the Terms of Service (last updated February 8, 2012).