Below is a list of Pennsylvania pleading rules that I send to the law clerks in our office. It is a good list to review whenever filing a document.
Pa.R.C.P. 204.1 provides formatting rules. Documents must be double spaced. This is a rule that is often broken.
Pa.R.C.P. 1007.1 is the rule on demanding a jury trial. All complaints should have a demand for a jury trial in the caption. Further, some counties (like Delaware) require a specific request for twelve jurors. If you don’t file it, you get eight. I’ve noticed that some defense counsel routinely file an entry of appearance with a specific demand for a jury trial of twelve with two alternates. This is probably the safest way to make sure you have the jury rules covered regardless of the county.
Pa.R.C.P. 1018 is the rule on captions.
Pa.R.C.P. 1018.1 is the rule on Notices to Defend. Note that some counties (like Montgomery) automatically produce a Notice to Defend when you file electronically, while other (like Philadelphia) do not.
Pa.R.C.P. 1019 is the rule on specificity in pleadings. You need to be specific enough that the defendant can respond and prepare a defense. You shouldn’t be too specific about irrelevant details. The client will sign a verification to the complaint. (Pa.R.C.P. 1024). If the specific, irrelevant details are later proved to be incorrect, the client can be cross-examined on the inconsistency.
If there is more than one defendant, make sure, in the “wherefore” clause, to plead that they are jointly and severally liable. This is important for recovery and sometimes for venue. (Pa.R.C.P. 1006(c)(1)).