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Plaintiffs C.G.1, C.G.2, C.G.3, N.G. S.K, K.H., K.J., M.M., L.E., L.C., and T.C.1 respectfully submit this memorandum of points and authorities in opposition to the District of Columbia (“D.C.”) and the DC Child and Family Services Agency’s (“CFSA”) (collectively, the “Defendants”) Motion to Dismiss Plaintiffs’ Complaint (the “Motion to Dismiss” or “Motion”). For the reasons stated herein, Defendants’ Motion to Dismiss should be denied.