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4055 Even in the absence of prior similar incidents, a bar-owner's special relationship to patrons may result in a duty to take undemanding, unburdensome measures, such as calling 9-1-1 or having existing security personnel escort them to their cars, to protect them against foreseeable attack by third persons; in such cases, the existence and extent of the owner's duty should be determined by consideration of the factors listed in Rowland v Christian.CitationDELGADO v TRAX BAR & GRILL (Parking Lot Attack) 36 C4 224 [See: Ann M v Pacific Plaza 6 C4 666, T/AT 2/94; Sharon P v Arman 21 C4 1181, T/AT 1/00; Delgado v Trax (RevGrtd) 109 CA4 262, T/AT 6/03; Rowland v Christian 69 C2 108 ]
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