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U.S. Courts Of Appeal

SECURITIES - The Ninth Circuit found that the SEC correctly claimed that Phan's use of stock registered only for employee compensation purposes - to raise capital from the public for the cash-strapped publicly traded company he led - violated securities registration requirements. However, the summary judgment record does not demonstrate that he made material misstatements. Reversed in part. SEC v. Phan

California Courts Of Appeal

NEGLIGENCE - J. Pollak finds that Center Point and Humboldt Recovery Center did not owe plaintiffs a legal duty of care to control the criminal behavior of the residents of their treatment facility. Plaintiffs claimed that the defendants were liable for the criminal behavior of four residents who stabbed plaintiffs in a nearby park after escaping from defendants' drug rehabilitation program. Rice v. Center Point, Inc.

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