Rule 3:18.General Provisions as to Pleadings.

This rule gathers a handful of general drafting rules that apply across Virginia pleadings. First, it settles a classification question: all written motions — including a motion for a bill of particulars and a motion to dismiss — count as pleadings, whether filed on paper or as electronic or digitally imaged filings.

Next come two pleading shortcuts tied to common defenses. An allegation of negligence, or of contributory negligence, doesn’t need to spell out the particulars — a general allegation is enough. The same goes for the statute of limitations: alleging that an action is time-barred is sufficient without identifying the specific statute relied on.

Contributory negligence gets one more rule of its own: it isn’t available as a defense unless it’s either pleaded or shown by the plaintiff’s own evidence at trial. A defendant can’t raise it as an afterthought if it was never pleaded and the plaintiff’s proof doesn’t establish it.

Finally, the rule addresses how filings can be organized. Answers, counterclaims, cross-claims, pleas, demurrers, affirmative defenses, and motions may all be combined into a single filing, as long as each one is separately identified in both the caption and the body of the document.