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P alleged that D wrongfully churned her account by engaging in excessive stock transactions on her behalf to generate brokerage commissions for their own gain. The complaint alleged many trades in detail and that P was close to retirement and had only AT&T stock acquired by her employment and that D induced her to engage in a series of transactions resulting in high brokerage fees and the loss of a large part of her capital. The complaint was made in considerable detail covering ten legal size pages. D moved for a more definite statement under Rule 9(b), 9(g), and 12(e).

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