800.08. Fraud and Deceit-Fraudulent Concealment-Issues Made by the Pleadings-One Defendant

800.08 Fraud and Deceit--Fraudulent Concealment--Issues Made by the Pleadings--One Defendant The plaintiff claims that the defendant knowingly [concealed from] [withheld from] the plaintiff the following fact[s]: [Here insert or paraphrase the alleged fact[s] claimed to have been concealed or withheld.] The plaintiff further claims that the fact[s] [concealed] [withheld] [was] [were] [a] material fact[s]. The plaintiff further claims that the defendant [concealed] [withheld] the fact[s] with the intent to deceive the plaintiff and to induce the plaintiff to [act] [describe what the plaintiff did, e.g., "buy the farm"]. The plaintiff further claims that he [acted] [describe what the plaintiff did, e.g., "bought the farm"] in justifiable reliance on the facts as he knew them. The plaintiff further claims that he sustained damages as a result of the [concealment] [withholding] of [a] material fact[s] by the defendant. The defendant [denies that he knowingly [concealed] [withheld] any material fact[s] from the plaintiff,] [denies that he [concealed] [withheld] any fact[s] with the intent to deceive the plaintiff or to induce the plaintiff to [act] [describe what the plaintiff did, e.g., "buy the farm"],] [denies that the plaintiff [acted] [describe what the plaintiff did, e.g., "bought the farm"] in justifiable reliance on the facts as he knew them,] [and] [denies that damage resulted to the plaintiff from his reliance on the facts as he knew them].