The plaintiff must plead those material facts essential to formulate a complete cause of action. If a material fact is omitted, a cause of action is not effectively pleaded. Material facts should be stated with certainty and precision and state the defendant's wrongful acts and the consequent damage: McGregor v. Holyrood Manor, 2014 BCSC 679 at paras. 7–8, aff’d 2015 BCCA 157.
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