plaintiff against Costanzo. We disagree. Pa.R.C.P. § 1028(a)(3) provides that preliminary objections may be filed for insufficient specificity in a pleading. The content of pleadings is governed by Pa.R.C.P. § 1019(a) which requires that “the material facts on which a cause of action or defense is based shall be stated in concise and summary form.” Pa.R.C.P. §1019(a). Pennsylvania is a fact pleading state. Pleadings in a fact pleading jurisdiction serve the purpose of putting an opponent on notice of what he will be called upon to meet at trial and to define the issues for trial. Mansour ex rel. Mansour v. Gnaden Huetten Memorial Hospital, 2007 WL 5234151 (Pa. Com. Pl.), 3 Pa. D. & C.5th 149; Estate of Swift v. Northwestern Hospital of Philadelphia, 690 A.2d 719, 723 (Pa. Super. 1996) (<HOLDING>). “The purpose behind the rules of pleading is
holding that a claim including a constitutional claim must have been asserted to the trial court to be raised on appeal holding that the allegations must apprise the defendant of the claim being asserted and summarize the essential facts to support the claim holding estoppel claim could not lie in tort where the facts that support the claim could not support a claim for fraud or misrepresentation holding that a wrongful death claim related back to a personal injury claim in an automobile accident case where the wrongful death claim  arose from the same transaction or occurrence as the original complaint and the defendant was advised of the essential facts necessary to prepare his defense even with the added claim recognizing the rule and the exception but holding facts did not support claim to exception