First year here: if a plaintiff’s complaints consistently has the number of their paragraphs wrong (ie paragraph 10 followed by paragraph 15), should I answer the complaint with “sic” and correct it or should my answer use the same numbers as Plaintiff’s?

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I usually drop a footnote that says we are following plaintiff’s numbering. For each mistake, I drop a footnote that plaintiff is referring to Paragraph 10 as Paragraph 15. And so on.

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[sic]

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[sick]

funny

Agree with others. You need to make it clear so you don’t risk waiver because of plaintiff’s stupidity. Also a good reason to reproduce the full paragraphs in your answer (in addition to making everyone’s life easier so you don’t have to have two documents open and cross reference).

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I've seen people say the correct number and then note what it was incorrectly labeled as. In your example, the 11th paragraph is labeled as "15." So the answer would go something like, With respect to the allegations in paragraph 11 (incorrectly numbered as paragraph 15)...

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You must respond to each line with a photo of the Count.
[also the footnote thing above is good too]

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funny

Awesome, thanks to the both of you for the quick responses

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