Every pleading shall consist of plain and concise statements in consecutively numbered paragraphs. Each paragraph shall contain, as far as practicable, a single allegation. Reference to and incorporation of allegations may subsequently be by number. Prior statements in a pleading shall be deemed repeated or adopted subsequently in the same pleading whenever express repetition or adoption is unnecessary for a clear presentation of the subsequent matters. Separate causes of action or defenses shall be separately stated and numbered and may be stated regardless of consistency. Causes of action or defenses may be stated alternatively or hypothetically. A copy of any writing which is attached to a pleading is a part thereof for all purposes.
R 3014.Statements.
Article 30. Remedies and Pleading · Last amended 1963 · Last verified July 21, 2026
In one sentenceFixes the required format for every New York pleading: plain, concise, numbered paragraphs, each stating a single allegation where practical, with causes of action or defenses separately numbered and free to be pleaded alternatively or even inconsistently.
Full Text of CPLR 3014
Plain-English Summary
Where CPLR 3013 sets how much a pleading must say, CPLR 3014 sets how it has to look. Every pleading is built from plain, concise, consecutively numbered paragraphs, and each paragraph should hold a single allegation as far as that's practical. Later paragraphs can refer back to earlier ones by number instead of restating them, and once matters are stated clearly the first time, a pleader doesn't need to repeat or expressly readopt them for them to carry forward — the rule eliminates the old boilerplate reciting that a paragraph “repeats and realleges every allegation” in the paragraphs before it.
Separate causes of action and separate defenses each get their own number, and a pleader isn't locked into one theory. Claims or defenses can be stated in the alternative or hypothetically, and they don't have to be consistent with one another — a plaintiff unsure whether a transaction was a sale or a loan, for example, can plead both and let the proof sort it out.
The last rule in this section resolves a recurring drafting question: when a pleader attaches a writing — a lease, a note, a contract — to the pleading, that document becomes part of the pleading for every purpose. There's no need for a separate sentence saying so, and a court considering the pleading on a motion can look to the attached document as part of what was pleaded.
Frequently Asked Questions
Do New York pleadings need numbered paragraphs?
Yes. CPLR 3014 requires plain and concise statements set out in consecutively numbered paragraphs, with each paragraph limited, as far as practicable, to a single allegation.
Can I plead inconsistent claims in the same New York lawsuit?
Yes. CPLR 3014 allows separate causes of action or defenses to be stated regardless of consistency with one another.
Can I state facts in the alternative if I'm not sure which version applies?
Yes. CPLR 3014 expressly permits causes of action or defenses to be pleaded alternatively or hypothetically.
Do I have to keep repeating “plaintiff repeats and realleges every prior paragraph” throughout a New York complaint?
No. CPLR 3014 treats prior statements as repeated or adopted later in the same pleading whenever that's clear without express repetition, making the old “repeats and realleges” recitation unnecessary.
If I attach a contract or lease to my complaint, is it treated as part of the pleading?
Yes. CPLR 3014 provides that a copy of any writing attached to a pleading is part of that pleading for all purposes.
How should I organize multiple causes of action in one New York complaint?
Each cause of action, and each defense in an answer, should be stated separately and given its own number under CPLR 3014, even where the claims overlap or conflict.
Advisory Committee Notes
The phrase “plain and concise” of this rule is taken from CPA § 241. The second and third sentences are based upon RCP 90. The restriction on the provision for incorporation by reference has been removed to permit reference and incorporation in other than the same pleading.
The fourth sentence of this rule is new. It is an extension of the provision of RCP 90 for incorporation by reference and permits elimination of the paragraphs of a pleading which “repeat and reallege each and every allegation contained in paragraph—to paragraph—inclusive with the same force and effect as if the same had been more fully set forth hereunder,” provided that such a recitation is not needed for clarity.
The next two sentences are simplifications of provisions contained in CPA §§ 258 and 262 and RCP 90. The rule as to joinder covers hypothetical as well as alternative causes of action or defenses, since the difference is often only one of form.
The remaining sentence is taken from Federal rule 10(c) and is intended to eliminate the usual allegation to that effect.
Amendment History
Add, L 1962, ch 308, § 1, eff Sept 1, 1963.
Source & verification. Provision text, History, and Advisory
Committee Notes are reproduced verbatim from the Consolidated Laws of New York.
Last verified July 21, 2026.
· Official source
Also known as: how to format a New York complaintnumbered paragraphs New York pleadingpleading in the alternative New Yorkrepeats and realleges New York pleadingseparately stated causes of action New York