Last year I wrote this post.
So, what good is it?
Look at this opinion and then this opinion. To my own way of thinking, that's how you want to use Rule 9 of the Federal Rules, which rule Middleditch and Sinclair says matches what Virginia law requires. Who knows what will come of that particular case, but it is much different from what I thought at the beginning.
Then again, sometimes I make these same arguments, and a judge somewhere says, nicely done, now go ahead and file your answer and let's get on with it.