Pursuant to plaintiff's motion for summary judgment, the court considered whether elements established and the standard of proof applied in a state court action against debtor satisfied the elements of non-dischargeable fraud under 11 U.S.C. § 523(a)(2)(A). The court concluded that the state court common law fraud findings were entitled to collateral estoppel effect, but that § 523 contained no provision that would allow the state court's assessment of punitive damages to become part of a non-dischargeable debt.