to pay the purchase price. 3.Pursuant to the Securities Purchase Agreement, dated September 2, 2004, Mer-vyn's Holdings purchased 100% of the interests in Holdings I and Holdings II for $429,746,414,84. At the closing, Mervyn’s Holdings used these funds to pay the purchase price. (Am.Compl.$ 58). 5 . Brandt v. Trivest II, Inc. (In re Plassein Int’l Corp.), 352 B.R. 36, (Bankr.D.Del.2006) ("Accordingly, the Court joins with those decisions that have (either implicitly or explicitly) evaluated fraudulent transfer complaints using Rule 8(a)(2)’s notice pleading standard”) Id. at 40-41. See. e.g., Giuliano v. U.S. Nursing Corp. (In re Lexington Healthcare Group, Inc.), 339 B.R. 570, 574-75 (Bankr.D.Del.2006) (applying "liberal notice pleading standard”); AstroPower, 335 B.R. at 333 (<HOLDING>); Official Comm, of Unsecured Creditors v. DVI
holding despite collective allegations in complaint the complaint was not deficient under rule 8a because it stated with sufficient particularity facts establishing a causal connection between the defendants actions and the constitutional deprivation holding that a fraudulent transfer complaint need only set forth the facts with sufficient particularity to apprise the defendant fairly of the charges made against him holding that the fraud claims against the defendant should not have been dismissed as the complaint provided him with fair notice of the claims made against her holding that the information must set forth each element of the crime that it charges as well as fairly inform a defendant of the charge against which he must defend holding that a criminal defendant is entitled to know the charges against him and to be tried solely upon the charges against him internal quotation marks and citation omitted