Federal Deception Law: 7.5.3.1.6 Pleading willfulness
The Federal Rules of Civil Procedure allow malice, intent, knowledge, and other conditions of a person’s mind to be alleged generally.609 However, pleading facts to support an allegation of willfulness—for example, that the defendant continued to make calls after requests to stop610—is always helpful. Pleading that the called party’s telephone number has always been a cell phone, that the caller’s website says its infrastructure a