If facts are adequately stated in one part of a pleading, or in any one pleading, they need not
be repeated elsewhere in the pleading, or in the pleadings, and may be incorporated by reference elsewhere or in other pleadings.
Rule 134.Incorporation of Pleadings by Reference
Article II. Rules on Civil Proceedings in the Trial Court · Part B. Pleadings and Other Papers · Not amended since adoption on record · Last verified July 20, 2026
In one sentenceRule 134 lets a party state facts once in a pleading and then refer back to them instead of repeating them throughout the document.
Full Text of Ill. S. Ct. R. 134
Plain-English Summary
Rule 134 is an efficiency rule for drafting pleadings. If a pleading already states facts adequately in one place, whether in one paragraph or one full pleading, the party does not have to restate those same facts elsewhere.
Instead, later sections of the pleading, or even separate pleadings, can incorporate those facts by reference. That keeps a complaint or answer from repeating the same background story count after count, while still giving every count the benefit of those facts.
Frequently Asked Questions
Do I have to repeat the same facts in every count of my complaint?
No. Rule 134 lets you state facts once and then incorporate them by reference wherever else they apply.
Can I incorporate facts from one pleading into a completely different pleading?
Yes, the rule allows incorporation by reference both within a single pleading and across separate pleadings.
Why would a lawyer use incorporation by reference instead of just repeating the facts?
It keeps pleadings shorter and easier to follow, avoiding the clutter of restating the same background facts in every count or section.
Does incorporating facts by reference weaken my pleading in any way?
No, as long as the facts were adequately stated the first time, referencing them elsewhere carries the same legal effect as repeating them.
Is there a special phrase required to incorporate facts by reference?
The rule does not prescribe specific wording; it permits the practice of referring back to facts already adequately pleaded.
Committee Comments
This is former Rule 11-1.
Source & verification. Rule text, official Committee Comments, and
amendment history are reproduced verbatim from the Illinois Supreme Court Rules,
promulgated by the Supreme Court of Illinois. Last verified July 20, 2026.
· Official source
Also known as: incorporation by reference pleadingrepeating facts in a complaintreferencing prior allegationspleading shortcuts illinoiscombining counts in a complaint