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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.... :)
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