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Motion To Dismiss Plaintiffs' Complaint
Motion To Dismiss Plaintiffs' Complaint
Plaintiffs,
Defendants.
Defendant, Robert N. Tracci, hereby moves to dismiss the complaint in its entirety. For
reasons more fully stated in the defendant's accompanying memorandum oflaw in support of
1. Count I be dismissed under Rule 12(b)(6)for failure to state a claim upon which relief
can be granted;
2. Count II be dismissed under Rule 12(b)(6) for failure to state a claim upon which relief
can be granted;
3. Count III be dismissed under Rule 12(b)(6) for failure to state a claim upon which relief
can be granted and for lack ofsubject-matter jurisdiction, because plaintiffs lack standing
4. Count IV be dismissed under Rule 12(b)(6) for failure to state a claim upon which relief
can be granted;
5. Count V be dismissed under Rule 12(b)(6) for failure to state a claim upon which relief
can be granted;
6. Count VI be dismissed under Rule 12(b)(6)for failure to state a claim upon which relief
can be granted;
7. Count VII be dismissed under Rule 12(b)(6) for failure to state a claim upon which relief
can be granted and for lack of subject-matter jurisdiction, because plaintiffs lack standing
8. Count VIII be dismissed under Rule 12(b)(6)for failure to state a claim upon which relief
can be granted.
CERTIFICATE OF SERVICE
I hereby certify that on July 16,2018,1 caused a true and accurate copy ofthe foregoing pleading to
be served on the following counsel ofrecord:
Jennifer Sandman
Planned Parenthood Federation of America
123 William Street
New York, NY 10038
Jennifer,[email protected]
By: // W </
Robert hfbira Tracci