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OPPOSITION TO MOTION TO DISMISS COMPLAINT
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2 remove this notice and all other notices before using this document.
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Plaintiff, ________________________, (Plaintiff) herein submits his Opposition to the
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Motion to Dismiss for failure to state a cause of action filed by Defendant, _____________________
6 (Defendant).
7 Plaintiff contends that his complaint does in fact allege sufficient facts to state a cause of
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action against Defendant, and does state the particular section, namely 523(a)(2) of the Bankruptcy
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Code, on which Plaintiff contends that the debt owed by Defendant is non-dischargeable. Therefore,
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the Court should deny Defendants Motion.
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12 The Opposition to the Motion will be based on this Opposition, the attached Memorandum of
13 Points and Authorities, and all pleadings and documents on file in Defendants bankruptcy case and
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this adversary proceeding.
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This Motion shall be based upon this Notice, the attached Memorandum of Points and
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Authorities, the complete files and records of this action, and such other evidence as may be
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Dated_________________________ _______________________________________
21 Any Attorney or Party
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OPPOSITION TO MOTION TO DISMISS COMPLAINT
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MEMORANDUM OF POINTS AND AUTHORITIES
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I.
5 STATEMENT OF FACTS
6 Plaintiff contends that Defendant is a debtor of Plaintiff, and that the debt is non-
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dischargeable based on the following.
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OPPOSITION TO MOTION TO DISMISS COMPLAINT