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Trial courts routinely require plaintiffs to file a reply under Federal Rule of Civil Procedure 7(a) to qualified immunity defenses. See Schultea v. Wood, 47 F.3d 1427, 1430, 1432 (5th Cir. 1995) (en banc). The Schultea court held that 'the [district] court may, in its discretion, insist that a plaintiff file a reply tailored to an answer pleading the defense of qualified immunity.' Id. at 1433-44. The district court need not allow any discovery at this point unless the 'plaintiff has supported his claim with sufficient precision and factual specificity to raise a genuine issue as to the illegality of defendant's conduct at the time of the alleged acts.' Id. at 1434.

The Schultea rule governing the Rule 7(a) reply is an instantiation of the more general principle that 'heightened pleading' is needed in qualified immunity cases. See id. at 1430. Heightened pleading requires allegations of fact focusing specifically on the conduct of the individual who caused the plaintiffs' injury. See Wicks v. Mississippi State Employment Servs., 41 F.3d 991, 995 (5th Cir. 1995). 'Vindicating the immunity doctrine will ordinarily require such a reply, and a district court's discretion not to do ...

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