800.01. Fraud and Deceit-Fraudulent Misrepresentation-Issues Made by the Pleadings-Fraud-One Defendant

800.01 Fraud and Deceit--Fraudulent Misrepresentation--Issues Made by the Pleadings--Fraud--One Defendant The plaintiff claims that the defendant made the following statement[s]: [Here insert or paraphrase the allegedly fraudulent statement or statements that the defendant is claimed to have made.] The plaintiff further claims that the statement[s] [was a] [were] false statement[s] of material fact[s]. The plaintiff further claims that the defendant [knew the statement[s] [was] [were] false] [or] [believed the statement[s] to be false] [or] [made the statement[s] in reckless disregard of whether [it was] [they were] true or false]. The plaintiff further claims that the defendant made the statement[s] with the intent to I duce the plaintiff to [act] [describe what the plaintiff did, e.g., "buy the farm"]. The plaintiff further claims that he reasonably believed the statement[s] and [acted] [describe what the plaintiff did, e.g., "bought the farm"] in justifiable reliance on the truth of the statement[s]. The plaintiff further claims that he sustained damages as the result of his reliance. The defendant [denies that he made [a] false statement[s] of [a] fact[s],] [denies that any [claimed] statement[s] [was] [were] material,] [denies that he [knew] [or] [believed] the [claimed] statement[s] to be false,] [denies that any [claimed] statement[s] [was] [were] made in reckless disregard of the statement['s][s'] truth or falsity,] [denies that he intended to induce the plaintiff to [act] [describe what the plaintiff did, e.g., "buy the farm"],] [denies that the plaintiff reasonably believed the [claimed] statement[s] or [acted] [describe what the plaintiff did, e.g., "bought the farm"] in justifiable reliance on the truth of the statement[s],] [and] [denies that damage resulted to the plaintiff from his reliance].