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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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To the extent the measure would create pressure to maintain the level of provider payments initially achieved by this measure, it could create pressure to use state General Fund monies to backfill the expected decline in funds available from this measure