Memorandum of Law in Support of Motion to Dismiss — No. 1:21-cv-00748 (Dkt. 33-1)

Summary

A memorandum of law filed November 9, 2021 as Document 33-1 by defendants Bank of America, N.A. and Megan Scholz in support of their motion to dismiss Natasha Athens d/b/a Favorite Things v. Bank of America and Megan Scholz, Civil Action No. 1:21-cv-00748-SM, in the U.S. District Court for the District of New Hampshire. It argues that the pro se complaint should be dismissed under Federal Rules of Civil Procedure 12(b)(6) and 9(b), that the CARES Act creates no private right of action, and that the fraud, breach of contract and emotional distress claims are inadequately pled. It states that the plaintiff's PPP loan of $18,625 was funded on May 14, 2020 and that forgiveness was denied because documents submitted with the forgiveness application showed she did not qualify. It is signed /s/ Thomas J. Pappas of Primmer Piper Eggleston & Cramer PC.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used