MEMORANDUM AND ORDER
McLAUGHLIN, District Judge.
In this action based on diversity of citizenship, 28 U.S.C. § 1332(a), defendant moves to dismiss the amended complaint for failure to state a claim. Fed.R.Civ.P. 12(b)(6). Defendant also makes the now obligatory application for sanctions under Fed.R.Civ.P. 11.
FACTS
1. The Amended Complaint
Assuming all allegations in the amended complaint are true, the facts are as...
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