(a) All pleadings shall contain a plain and concise statement of the pleader's cause of action, counterclaim, defense, or reply. (b) Each separate cause of action upon which a separate recovery might be had shall be stated in a separate count or counterclaim, as the case may be and each count, counterclaim, defense or reply, shall be separately pleaded, designated and numbered, and each shall be divided into paragraphs numbered consecutively, each paragraph containing, as nearly as may be, a separate allegation. (c) Pleadings shall be liberally construed with a view to doing substantial justice between the parties.
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