In my prior column within the ongoing attorney liability series, I discussed the importance of pleadings. That is, it is important to plead with hyper-specificity notwithstanding it is well-settled in Pennsylvania that factual conclusions suffice to surmount the inevitable preliminary objections for lack of specificity. Specificity in pleadings is important not only to overcome preliminary objections but also as to any and all objections that may arise during litigation and at trial.
Post-verdict or pre-verdict dismissal—in whole or in part—pleadings form the foundation for appellate preservation.
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