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Pleading Causes of Action for the Maryland Lawyer 7th Edition

Lawyer and judge on opposites sides of a table

With the recent release of the new 7th Edition of PCAM, my mind traveled back in time to why and how this book was created. In the late 70s when I was a young lawyer working as an associate, there were few law books to read and learn. The population of the Bar was small. Often the senior lawyers would help the younger group. For example, I remember in a deposition I was having difficulty properly phrasing a question. One of the senior attorneys Fred Green went off the record and said: “Paul, ask the question this way” demonstrating the correct phraseology.

It was during this era that I received a phone call from a colleague, who asked me a question about drafting a pleading. I could not answer it. I could not find the answer anywhere. I vividly remember this conversation so long ago, because it led me to think that I could write a book on pleadings. So it began. Every night I would work – research and write. Two years went by, and I was not even halfway finished. One day at an ABA meeting in Colorado Springs, I was sitting outdoors on a bench worrying about my lack of progress. Suddenly Ben Civiletti appeared. He said, “Paul, it looks like you have the weight of the world on your shoulders. What is wrong?” I explained that I was writing a book on Pleading Causes of Action for Maryland Lawyers. I was not making progress because of my “Day Job.” He said that I needed a co-author. Replying I said that co-authors don’t work. “This one will,” he replied. “Whom do you have in mind?” I inquired. He then asked me where I would be the next Monday at 9:00 AM. I told him in my office. He told me that at exactly 9:00 AM on that Monday I should put my hand on the phone. It would ring as my new co-author would be calling me. And so I met James K. Archibald. He and I have become good friends and co-authors of the PCAM for decades. And now with the 7th Edition, we are joined by a third co-author Eleanor T. Chung.

For those not familiar with the book, we explain based on rules and case law how to plead almost every cause of action in Maryland. Our format consists of hypothetical facts relating to a cause of action, a model complaint, commentary on the law and practical features of pleading and responding to the complaint. Some of the highlights of our new 7th Edition include new causes of action: Breach of Fiduciary Duty and Intentional Interference with an Inheritance or Gift. It adds and amends causes of action and model complaints based on statutory enactments and amendments and case law on various causes of action. The Seventh Edition also includes two new chapters: Complaints to Enforce Arbitration, and Interpleader. Hundreds of cases are cited as well as pertinent rules and statutes.