It is not very hard to plead cases under the Federal Rules of Civil Procedure. However, some rules are honored more in the breach. Take Fed.R.Civ.P. 8(a)(2) which requires a "short and plain statement of the claim." A short and plain statement makes it easier to draft a responsive answer without having to diagram sentences and categorize cross-references.
Some judges have pet peeves when it comes to pleadings. For Chief Judge Eduardo Rodriguez, one is a "shotgun" pleading. One form of shotgun pleading is one where each claim incorporates everything which came before it. If a claim to determine lien priority against Defendant C incorporates an objection to claim against Defendant A, it it is no longer a short and plain statement. Faced with a complaint which included a count which incorporated all the counts that came before it, Judge Rodriguez struck the entire pleading as an impermissible shotgun pleading.
When a pleading sets forth a statement of facts, it should be relatively obvious that the later claims for relief rely on those facts. However, if you find it absolutely necessary to incorporate prior material, it is better to just incorporate the facts and not the other claims for relief. This will avoid having your pleading struck as a shotgun pleading.
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