Is a defendant required to refer to a prior pleading in order to make an amended pleading complete?

Defendant is also reminded that the court cannot refer to a prior pleading in order to make an amended pleading complete. Local Rule 220 requires that any amended counterclaim be complete in itself without reference to prior pleadings. The second amended counterclaim will supersede the amended counterclaim, just as the amended counterclaim superseded the original counterclaim. See Loux v. Rhay, 375 F.2d 55, 57 (9th Cir. 1967). Thus, in an amended counterclaim, just as if it were the initial counterclaim filed in the case, each counter-defendant must be listed in the caption and identified in the body of the counterclaim, and each claim and the involvement of each counter-defendant must be sufficiently alleged. Any amended counterclaim which defendant may elect to file must also include concise but complete factual allegations describing the conduct and events which underlie defendant's claims.