Guy v. Baer

The complaint must contain a plain and concise statement of the facts constituting a cause of action, without unnecessary-repetition; and each material allegation must be distinctly numbered. G-.S. 1-122.

The function of a complaint is not the narration of the evidence but the statement of the substantive and constituent facts upon which the plaintiffs’ claim to relief is founded. Winders v. Hill, 141 N.C. 694; Brown v. Hall, 226 N.C. 732, 40 S.E. 2d 412. Hence, “the facts constituting a cause of action” required by the statute are the material, ■essential, and ultimate facts which constitute…