[jude24]

A complaint doesn't need to allege evidence. The Federal Rules of Civil Procedure require only a short, plain statement showing that the plaintiff is entitled to relief, and the complaint is construed at this stage in litigation in the way most beneficial to the plaintiff. This could survive a 12(b)(6) motion for dismissal because it passes this test.

The plaintiff doesn't need to reveal specific evidence in her complaint; the plaintiff and her attorneys need to be able to demonstrate that the pleading is consistent with the information derived from a reasonable inquiry. FRCP 11(b). The plaintiff actually wouldn't want to divulge too much evidence at this stage yet; that will happen during discovery when both sides give each other what they know.

Marlowe will be able to tell you if I paid enough attention in civil procedure.

[P-Marlowe]

A complaint doesn't need to allege evidence.

Correct grasshopper. (Are you already studying Civ Pro?)

In a complaint you merely allege the facts that you intend to prove at trial. Whether you have the evidence to prove up the facts is for the jury to decide. The complaint must contain enough alleged "facts" to establish that there is a legitimate cause of action.