Read the following excerpt from a US court opinion:
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The movant carries the burden of demonstrating that dismissal is appropriate. Intel Corp., 496 F.Supp.2d at 408. However, Bankruptcy Rule 7009 further provides that Fed.R.Civ.P. 9 applies in adversary proceedings. While Fed.R.Civ.P. 9(b) provides that: “all averments of fraud or mistake, the circumstances constituting fraud or mistake shall be stated with particularity,” Rule 9(b) only applies to allegations of actual fraud. Furthermore, this Court takes the view that claims of constructive fraud, i.e. fraudulent transfers, are evaluated using Rule 8(a)(2). A fraudulent transfer complaint “need only set forth the facts with sufficient particularity to apprise the defendant fairly of the charges made against him.” In re Astro-Power Liquidating Trust, 335 B.R. 309, 333 (Bankr.D.Del.2005) . Fed.R.Civ.P. 8(a), made applicable to this
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What is the most suitable continuation to the opinion? Your options are:
A. recognizing that the federal pleading standard is a less stringent standard than the delaware pleading standard
B. 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
C. holding that a constructive fraud count need not comply with rule 9s heightened pleading standard
D. 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
E. holding that heightened pleading standards do not apply to defamation actions
Reply with [A, B, C, D, E] only.