
Pleadings pro tip: if you don't plead to it then you admit it
I am constantly seeing paragraphs in defences saying something to the effect of: "The defendant does not plead to paragraph [X] of the statement of claim because it makes no allegation against the defendant." There are two problems with that. The first is that you are probably wrong. Every paragraph in the statement of claim makes an allegation against the defendant. Even if you are one of multiple defendants and the paragraph seems to concern one of the other defendants, you