manner and form

from Bouvier's Law Dictionary, Revised 6th Ed (1856)
MANNER AND FORM, pleading. After traversing any allegation in pleading, it 
is usual to say "in manner and form as he has in his declaration in that 
behalf alleged," which is as much as to include in the traverse, not only 
the mere fact opposed to it, but that in the manner and form in which it is 
stated by the other party. These words, however, only put in issue the 
substantial statement of the manner of the fact traversed, and do not extend 
to the time, place, or other circumstances attending it, if they were not 
originally material and necessary to be proved as laid. 3 Bouv. Inst. p. 
297. See Modo et forma. 
    

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