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3197 REVIEW DENIED In a negligence action based on the allegation that defendant failed to take adequate security precautions to protect plaintiff from assault by third persons on defendant’s premises, plaintiff fulfills the burden of proving causation by showing that the security precautions defendant failed to take probably would have prevented the assault (i.e., that it is more likely than not that the assault would not have occurred if the precautions had been taken).CitationSANDOVAL v BANK OF AMERICA (Parking Lot Assault) 94 CA4 1378 [See: Ann M v Pacific Plaza 6 C4 666, T/AT 2/94; Saelzler v Advanced 25 C4 763 T/AT 6/01]
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