(1) A defence to a personal injuries action shall specify -

(a) the allegations specified, or matters pleaded, in the personal injuries summons of which the defendant does not require proof,

(b) the allegations specified, or matters pleaded in the personal injuries summons of which he or she requires proof,

(c) the grounds upon which the defendant claims that he or she is not liable for any injuries suffered by the plaintiff, and

(d) where the defendant alleges that some or all of the personal injuries suffered by the plaintiff were occasioned in whole or in part by the plaintiff's own acts, the grounds upon which he or she so alleges.

(2) A counterclaim in a personal injuries action shall specify -

(a) the personal public service number allocated and issued to the defendant under section 223 (inserted by section 14 of the Act of 1998) of the Act of 1993,