Barring exclusion by the Court, this attachment could possibly convert the motion to dismiss into one for summary judgment. See Fed.R.Civ.P. 12(b). Under the Third Circuit's recent opinion in Pension Benefit Guaranty Corp. v. White Consolidated Industries, Inc., however, the Court may consider the agreement, notwithstanding its introduction into the record via the motion to dismiss, since Loftus's claim is based on the agreement. See 998 F.2d 1192, 1196 (3d Ci r to have read Leatherman to have eliminated the requirement of "heightened specificity” in all § 1983 actions including those against individual government officials, albeit without much discussion. See, e.g., Holloway v. Watson, Civ. A. No. 93-4436, 1993 WL 328589, at *1 (E.D.Pa. Aug. 27, 1993); Piazza, 831 F.Supp. at 428 (<HOLDING>); Lassiter v. Kalp, Civ. A. No. 93-1176, 1993
recognizing the liberal notice and simplified pleading principles underlying the federal rules of civil procedure holding that under leatherman a federal court may not apply a pleading requirement more stringent than that provided for in the federal rules of civil procedure even in  1983 litigation holding that a court may not apply a heightened pleading standard more stringent than the usual pleading requirements of rule 8 in civil rights cases alleging municipal liability under  1983 holding that the fact that federal rule of civil procedure 9b requires a heightened pleading standard for some claims but not for a section 1983 claim against a municipality means that the rules do not require a heightened pleading standard for such a claim holding that a shotgun pleading is in no sense the short and plain statement of a claim required by rule 8 of the federal rules of civil procedure