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                    UNITED STATES DISTRICT COURT
                    NORTHERN DISTRICT OF [REDACTED]

[PLAINTIFF],                              Case No. ██-CV-█████
        Plaintiff,
v.                                        DEFENDANT'S NOTICE OF MOTION
                                          AND MOTION TO DISMISS
[DEFENDANT],                              PURSUANT TO FED. R. CIV. P.
        Defendant.                        12(b)(6)

                                          Hearing: [DATE], [TIME]
                                          Judge:   Hon. [JUDGE]
                                          Ctrm:    [COURTROOM]

TO PLAINTIFF AND PLAINTIFF'S COUNSEL OF RECORD:

PLEASE TAKE NOTICE that on the date and time set forth above, or
as soon thereafter as counsel may be heard, Defendant [DEFENDANT]
will and hereby does move this Court for an order dismissing
Plaintiff's Complaint in its entirety, with prejudice, for failure
to state a claim upon which relief can be granted.

I.   INTRODUCTION

Plaintiff's Complaint fails as a matter of law. Even accepting
every factual allegation as true and drawing all reasonable
inferences in Plaintiff's favor, the pleading does not establish
the essential elements of any cognizable cause of action.

II.  STATEMENT OF FACTS

On or about [DATE], the parties entered into the agreement that
forms the basis of this dispute. Plaintiff alleges that Defendant
breached the agreement on [DATE]; however, the Complaint identifies
no provision of the agreement that Defendant is alleged to have
breached, nor any cognizable damages flowing from the alleged
breach.

III. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that this Court:

    1.  Dismiss Plaintiff's Complaint in its entirety, with
        prejudice;
    2.  Award Defendant its costs and attorneys' fees incurred
        in this action; and
    3.  Grant such other and further relief as the Court deems
        just and proper.

Dated: [DATE]                       Respectfully submitted,

                                    /s/ [ATTORNEY NAME]
                                    [ATTORNEY NAME] (Bar No. ██████)
                                    [LAW FIRM]
                                    [ADDRESS]
                                    Tel: ███-███-████
                                    Email: [EMAIL]

                                    Attorney for Defendant
                                    [DEFENDANT]