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delay between your follow ups and my reply while I am typing out my answer. 1.) Second paragraph, titled JURISDICTION. I am adding this to my special exceptions. I have the verbiage under the main special exceptions titled, "Subject to and without waiver of her motion
to transfer venue,". Do I need to add it to every special exception?
While there is no hard and fast rule, it is best to do so when in doubt.2.) In general, with my special exceptions, do I need to ask for something or leave that up to the petitioner to figure out?
No, the Respondent
wants to ask for a remedy from the Court for each special exception. I have stated why the pleading is in error/untrue but do I need
to tell them what it should be corrected to?
I am afraid that untruths generally cannot fall under special exceptions. Special exceptions are reserved for things like ambiguous language, or, or, not sufficiently identify the facts and basis supporting Petitioner's allegations.
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