In any ethylene oxide-related action: (1) the complaint shall: (a) plead each element of the plaintiff's claim with particularity; and (b) plead each alleged act or omission constituting gross negligence or willful misconduct that resulted in personal injury, harm, damage, breach, or tort with particularity; (2) if monetary damages are requested, a plaintiff shall file with the complaint a statement of specific information as to the nature and amount of each element of damages and the factual basis for the damages calculation; and (3) if a claim is asserted on which the plaintiff may prevail only on proof that the defendant acted with a particular state of mind, a plaintiff shall file with the complaint, with respect to each element of that claim, a statement of the facts giving rise to a strong inference that the defendant acted with the required state of mind.
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