Introduction
The general allegations part of the Complaint are sometimes called Common Allegations, Facts, Jurisdiction, or at times they are incorporated into the First Cause of Action (as kind of a preamble to that initial claim). In fact, some attorneys do not title those paragraphs at all. Just go with the flow of your supervising attorney or, in this case, your instructor.

The examples on these next few sections in the manual are individual elements that make up the complaint. Use these examples. Use the examples in the Legal Writing Labs. Then when you begin working in a law firm, use forms and templates that the firm already possesses.

The skill you are developing is form manipulation. Using previously existing documents to create new material. Developing this skill will make your final product much better, and will make your life much easier.

Paralegal Perspectives . . .

COMMON ALLEGATIONS (a/k/a General Allegations)
For a paralegal, it is helpful to think of the general allegations as the simple set of facts that led to the matter being before the court. It is these facts that are the basis for all the claims for relief (causes of action) that will follow.