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Rule 55.11.Averments, How Made.

Part I · Rule 55: Pleadings, Motions and Hearing · Last amended September 1, 1973 · Last verified July 22, 2026

In one sentenceRule 55.11 requires averments to be stated in numbered paragraphs limited so far as practicable to a single set of circumstances, referenceable by number in later pleadings, and requires each claim from a separate transaction and each defense other than a denial to get its own count when separation aids clarity.

Full Text of Rule 55.11

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All averments of claim or defense shall be made in numbered paragraphs, the contents of each of which shall be limited as far as practicable to a statement of a single set of circumstances; and a paragraph may be referred to by number in all succeeding pleadings. Each claim founded upon a separate transaction or occurrence and each defense other than denials shall be stated in a separate count or defense whenever a separation facilitates the clear presentation of the matters set forth.

Amendment History

Adopted Jan. 19, 1973, eff. Sept. 1, 1973.

Official Comment

This is the same as prior Rule 55.13. Compare: Rule 10(b) of the Federal Rules of Civil Procedure.

Plain-English Summary

Every averment of a claim or defense goes into a numbered paragraph, and each paragraph should be limited, as far as practicable, to a single set of circumstances. Numbering matters because it lets later pleadings reference an earlier paragraph by number instead of restating it, keeping the case file easier to track across rounds of pleading.

The rule also calls for separation at a higher level: each claim founded on a separate transaction or occurrence, and each defense other than a plain denial, should get its own count or defense whenever separating them makes the case clearer. It’s a flexibility standard instead of a rigid rule — separation is required when it facilitates clear presentation, not in every conceivable case.

Frequently Asked Questions

Do Missouri pleadings need numbered paragraphs?

Yes. Rule 55.11 requires averments to be stated in numbered paragraphs, each limited so far as practicable to a single set of circumstances.

Can I reference a paragraph number from an earlier pleading?

Yes, the rule specifically allows referring to a paragraph by number in later pleadings.

When must I use separate counts for different claims?

Whenever separation facilitates the clear presentation of the matters, particularly for claims founded on separate transactions or occurrences.

Do defenses need to be stated in separate counts too?

Yes, each defense other than a denial should be separately stated when doing so aids clarity.

What’s the purpose of numbered paragraphs under this rule?

To organize the pleading around discrete factual circumstances and make it easy to reference specific averments later in the case.

Source & verification. Rule text and amendment history are reproduced verbatim from the Missouri State & Federal Court Rules, adopted by the Supreme Court of Missouri. Last verified July 22, 2026. · Official source
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