Rule 16.Form of Pleadings

Rule 16 governs how a pleading is put together, not what it has to say. Every pleading needs a caption with the court’s name, the case title, and the register number of the case, along with the case designation Rule 13 B requires. A complaint has to name every party in its title; later pleadings can shorten that to the first-named party on each side. A party is ordinarily identified by name, though the rule allows a party to ask the court for permission to proceed under a pseudonym when the law otherwise allows it.

The body of a pleading must be broken into plain, concise, consecutively numbered paragraphs, each limited so far as practical to a single set of circumstances — later pleadings can then refer back to a paragraph by its number. Each distinct claim or defense has to be stated separately, and if a claim rests on more than one legal theory, each theory becomes its own count.

Rule 16 also gives parties room to plead broadly. Inconsistent claims or defenses aren’t a problem, and a party unsure which of two versions of the facts is true may allege both in the alternative. A party can raise as many separate claims or defenses as it has, regardless of whether they’re consistent with each other or rest on legal or equitable grounds — subject always to the good-faith obligations Rule 17 imposes on everything a party files. And a pleading may adopt a statement made elsewhere in the same pleading by referring back to it, rather than repeating it.