This document is an opposition to a motion to dismiss a complaint filed in a bankruptcy case. It argues that the plaintiff's complaint alleges sufficient facts to state a valid cause of action under Section 523(a)(2) of the Bankruptcy Code for non-dischargeability of debt based on false representations made by the defendant. The opposition contends the complaint satisfies the particularity requirements to plead fraud by identifying the alleged false statements, when and where they were made. It asks the court to deny the motion to dismiss as the plaintiff may be able to prove facts entitling them to relief.