Amendments to ws

If issues have not been framed, the court may allow your prayer with costs.  You move an amendment application alongwith the amended written statement saying that due to overlook you failed to put all the facts properly in the earlier written statement.

Instead of an amendment you can file an additional statement containing the additional information denying the allegations which were left out in the main written statement.

Thanks to the learned members for their valuable advices.

Finally, I am going with an amendment as of now.. 

Some queries for the learned members..

1) Some paras no date, time or place of the alleged incidents of cruelty is mentioned - I had denied the para in toto and stated that they are based on false and fabricated facts. Do I need to deny it specifically in the amended ws. Or it is not required as specific date or place is not mentioned.

2) Specific allegations is put in para A.. say respondent scolded me and said so and so on such date. However, in para B, I had denied in a more general way that I had never scolded petitioner. Can para B be referred in argument of para A. 

3) If allegation is spercific, can a general denial work.. say allegation is respondent beat petitioner and scolded so and so and stared at her.. Will it be sufficient to say in the reply to the para.., respondent never beat petitioner and never harassed her.

I am asking this because my lawyer is saying that we should have minimal changes in our amendment. I had around 50 changes including typological errors, new and amended submissions, new and amended denials.

Thanks, in advance.