Rule 1:4 - General Provisions as to Pleadings(a) Counsel tendering a pleading gives his assurance as an officer of the court that it is filed in good faith and not for delay.(b) A pleading that is sworn to is an affidavit for all purposes for which an affidavit is required or permitted. (c) Counsel or an unrepresented party who files a pleading must sign it and state his address.(d) Every pleading must state the facts on which the party relies in numbered paragraphs, and it is sufficient if it clearly informs the opposite party of the true nature of the claim or defense.(e) An allegation of fact in a pleading that is not denied by the adverse party's pleading, when the adverse party is required by these Rules to file such pleading, is deemed to be admitted. A denial must fairly respond to the substance of the allegation. A party that intends in good faith to deny only part of an allegation must admit the part that is true and deny the rest. An allegation in a pleading that the party does not know whether a fact exists will be treated as a denial that the fact exists.(f) Requirements of pleadings applicable to instruments not under seal apply to instruments under seal.(g) Requirements of pleadings applicable to legal defenses apply to equitable defenses.(h) The clerk must note and attest the filing date on every pleading. In an Electronically Filed Case, the procedures of Rule 1:17 apply to the notation by the clerk of the date of filing.(i) The mention in a pleading of an accompanying exhibit, of itself and without more, makes such exhibit a part of the pleading. Filing of such exhibits is governed by Rule 3:4. (j) Brevity is enjoined as the outstanding characteristic of good pleading. In any pleading a simple statement, in numbered paragraphs, of the essential facts is sufficient.(k) A party asserting either a claim, counterclaim, cross-claim, or third-party claim or a defense may plead alternative facts and theories of recovery against alternative parties, provided that such claims, defenses, or demands for relief so joined arise out of the same transaction or occurrence. When two or more statements are made in the alternative and one of them if made independently would be sufficient, the pleading is not made insufficient by the insufficiency of one or more of the alternative statements. A party may also state as many separate claims or defenses as he has regardless of consistency and whether based on legal or equitable grounds. (l) Every pleading, motion or other paper served or filed must contain at the foot the Virginia State Bar number, office address and telephone number of the counsel of record submitting it, along with any electronic mail (E-mail) address and facsimile number regularly used for business purposes by such counsel of record.Amended by order dated March 1, 2011, effective 5/2/2011; amended by order dated November 1, 2012, effective 1/1/2013; amended by Order dated November 1, 2012; effective 1/1/2013; amended by order dated September 3, 2020, effective 9/3/2020; amended by order dated November 23, 2020, effective 3/1/2021; amended by order dated June 21, 2024, effective 8/20/2024.