By Rachel Cooper and Madeline Klimek ( May 9, 2023, 1:48 PM EDT) -- Every litigator has likely faced a “boilerplate” pleading. It is a pleading not drafted to target the particular claim or defence, but merely fulfils the procedural groundwork to start or defend an action. However, these types of pleadings come at a cost. Mainly, the time and expense of amending them when new and important facts arise....