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3827 REVIEW DENIED In a certified class action, counsel owes class members a duty to consider amending the class action complaint to include theories that became viable because of changes in the law that occurred after class certification, if those theories arise from the circumstances underlying the certified class action.CitationJANIK v RUDY, EXELROD & ZIEFF (Class Counsel's Duty) 119 CA4 930 [See: B&PC 17200; Stanley v Richmond 35 CA4 1070, T/AT 7/95; Nichols v Keller 15 CA4 1672, T/AT 9/93; Cortez v. Purolator 23 C4 163, T/AT 7/00]
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