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The best way to dismiss a motion to dismiss a claim in a court of law is to state a prima facie cause of action. That means, if you have a valid legal claim that supports the facts of your case, then the motion to dismiss will be denied. Also, in case you filed a claim in the wrong court jurisdiction, filing a motion to change venue to the correct jurisdiction may also avoid a motion to dismiss a claim.
A motion to dismiss a claim is due to claiming some facts that has no legal basis, nor any means for relief.
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