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Plaintiff John Smith submits this Memorandum of Law in support of his Motion to Dismiss the counterclaims filed by Defendant Robert Jones, pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure. The counterclaims fail to state a claim upon which relief can be granted, as evidenced by @@
24.11.23 Contract.pdf
24.11.11 Letter.pdf

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  • 24.11.23 Contract.pdf

On April 1, 2025, Plaintiff entered into a written agreement with Defendant for the purchase of real property located at 123 Main Street, New York, NY 10001.

Defendant failed to disclose a lien on the property, discovered during a title search on April 10, 2025.

MentionComment

Plaintiff promptly notified Defendant of the issue and demanded resolution, but Defendant refused to address the lien, breaching the agreement.

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Summarize 24.11.23 Contract.pdf
The contract, dated April 1, 2025, involves the purchase of 123 Main Street, New York, NY 10001, between John Smith (Plaintiff) and Robert Jones (Defendant). It stipulated that Defendant would deliver clear title by April 15, 2025. A lien was discovered on April 10, 2025, which Defendant failed to disclose, leading to a breach of the agreement.

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