Hill v. HILL SPINNING COMPANY

We need not consider whether it was permissible for defendant to allege as a counterclaim or defense the same facts it had alleged in its said prior action. Suffice it to say, defendant has not alleged such facts.

In a complaint, if plaintiff undertakes to allege two or more separately stated causes of action, each must be complete within itself. It is not permissible to incorporate by reference allegations made in another separately stated cause of action. Heath v. Kirkman, 240 N.C. 303, 82 S.E. 2d 104, and cases cited. A fortiori, it is not permissible for a plaintiff to incorporate by…