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In lieu of flowers, it is suggested that donations be made to the Larry Rickles Endowment Fund at Childrens Hospital Los Angeles

As three other appellate courts recognize, because of the unique nature of the concealment conspiracy by the Engle defendants (tobacco companies), the progeny plaintiffs are not required to prove that they relied upon any specific misleading statements to establish their fraud-based claims, the estates brief said

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Second, smoking habits were self-reported through questionnaires rather than confirmed through biochemical methods, such as urine cotinine levels, which may lead to recall, misclassification, and measurement errors

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