Rule 2.113.Form, Captioning, Signing, and Verifying of Documents

Current through May 1, 2026 · Last verified July 6, 2026

In one sentenceRule 2.113 sets the mechanical formatting rules for pleadings -- numbered paragraphs limited to a single set of facts, separate counts for separate claims, and when a written instrument must be attached as an exhibit -- while pointing to MCR 1.109 for the underlying signature and verification requirements.

Full Text of Rule 2.113

Text sizeJump to: (A) (B) (C) (D)

(A) Applicability. The form, captioning, signing, and verifying of all documents are prescribed in MCR 1.109(D) and (E).

(B) Paragraphs; Separate Statements.

(1) All allegations must be made in numbered paragraphs, and the paragraphs of a responsive pleading must be numbered to correspond to the numbers of the paragraphs being answered.

(2) The content of each paragraph must be limited as far as practicable to a single set of circumstances.

(3) Each statement of a claim for relief founded on a single transaction or occurrence or on separate transactions or occurrences, and each defense other than a denial, must be stated in a separately numbered count or defense.

(1) If a claim or defense is based on a written instrument, a copy of the instrument or its pertinent parts must be attached to the pleading and labeled according to standards established by the State Court Administrative Office unless the instrument is

(a) a matter of public record in the county in which the action is commenced and its location in the record is stated in the pleading;

(b) in the possession of the adverse party and the pleading so states;

(d) of a nature that attaching the instrument would be unnecessary or impractical and the pleading so states, giving the reason.

(2) An attachment or reference to an attachment under subrule (C)(1)(a) or (b) is a part of the pleading for all purposes.

(D) Adoption by Reference. Statements in a pleading may be adopted by reference only in another part of the same pleading.

Amendment History

Michigan tracks the orders that adopt and amend its Court Rules in a separate administrative record rather than printing a history note beneath each rule in the compiled rules text reproduced here. The text above is verified current through the source’s own May 1, 2026 update; for the full order-by-order history of this rule, see the Michigan Supreme Court’s rules and orders page.

Plain-English Summary

Rule 2.113 is about structure, not substance. Every allegation in a pleading must sit in its own numbered paragraph, and a responsive pleading must number its paragraphs to line up with the ones it is answering. Each paragraph should, as far as practical, cover only a single set of circumstances, and each distinct claim or defense (other than a simple denial) needs its own separately numbered count. A pleading can only adopt earlier statements by reference within that same pleading — it cannot borrow language from an entirely separate filing.

When a claim or defense rests on a written instrument — a contract, note, or similar document — a copy of it (or the relevant part) generally has to be attached and labeled to the court's standards. There are practical exceptions: the instrument does not need to be attached if it is a public record and the pleading says where to find it, if the other side already has it and the pleading says so, if it is truly inaccessible to the filer (with the reason stated), or if attaching it would be unnecessary or impractical for a stated reason. When an instrument is attached under one of the first two exceptions, it becomes part of the pleading for every purpose.

The rule leaves the format, captioning, signing, and verification of documents generally to Rule 1.109, keeping Rule 2.113 focused narrowly on how a pleading's content should be organized.

Frequently Asked Questions

Do I have to attach a copy of a contract I'm suing on?

Generally yes, if your claim or defense is based on a written instrument like a contract or note, unless it is a public record you can point to, already in the other side's possession, truly inaccessible to you, or impractical to attach, each with the reason stated in the pleading.

Can I just adopt facts from an earlier document I filed in a different case?

No. Rule 2.113 only allows adopting statements by reference within the same pleading, not by borrowing language from a separate filing.

Why does each claim need its own numbered count?

So the pleading clearly separates distinct claims or defenses arising from a single transaction or from separate transactions, which keeps the case organized and makes it easier for the other side to respond to each one.

Source & verification. The rule text is reproduced verbatim from the official Michigan Court Rules (MCR 2.113). Prescribed by the Supreme Court of Michigan (Mich. Const. 1963, art. VI, § 5). The plain-English summary is original and written by us. Last verified July 6, 2026. · Official source

Also known as: numbered paragraphs pleading Michiganattaching written instrument to complaintseparate counts requirement