Where separate and distinct causes of action, as distinguished from separate and distinct claims for relief founded on the same cause of action or transaction, are joined, the statement of the second shall be prefaced by the words Second Count, and so on for the others; and the several paragraphs of each count shall be numbered separately beginning in each count with the number one.
Section 10-26.Separate Counts
Current through August 12, 2025 (2026 Practice Book edition) · Last verified July 9, 2026
In one sentenceWhen a complaint joins two or more separate and distinct causes of action, this rule requires each one after the first to be introduced with a heading like Second Count, with paragraphs in every count numbered starting over at one.
Full Text of Section 10-26
Amendment History
(P.B. 1978-1997, Sec. 138.)
Plain-English Summary
This section covers pleadings that join separate and distinct causes of action — not just separate claims for relief arising from the same transaction, but distinct causes of action stated together in one complaint. When a complaint does this, the statement of the second cause of action must be prefaced with the words “Second Count,” and each additional cause of action that follows gets its own heading in the same pattern.
Within each count, the paragraphs start their own numbering at one. A reader working through a multi-count complaint can always tell which count a given paragraph belongs to, because the numbering resets rather than running continuously from the first count through the last.
Frequently Asked Questions
Does every complaint need separate counts?
No. This rule applies only when a complaint joins separate and distinct causes of action, not when it states separate claims for relief arising from the same cause of action or transaction.
How should the second cause of action be labeled?
It must be prefaced with the words “Second Count,” and any further causes of action follow the same labeling pattern — Third Count, Fourth Count, and so on.
Does paragraph numbering carry over from one count to the next?
No. Each count starts its own paragraph numbering at one, rather than continuing the numbering from the prior count.
Source & verification. The section text is reproduced verbatim from the
official Connecticut Practice Book (Conn. Practice Book § 10-26). Prescribed by the Judges of the Superior Court of Connecticut (Conn. Gen. Stat. Section 51-14). The plain-English summary is original and written by us. Last verified July 9, 2026. ·
Official source
Also known as: second count complaint Connecticuthow to number paragraphs in a multi-count complaintseparate causes of action pleading CTlabeling counts in a Connecticut complaint