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St. Clair v. City of Chico 880 F.2d 199 201 9th Cir. 1989 see also White v. Lee 227 F.3d 1214 1242 9th Cir. It has suffered an injury in fact. Friends of the Earth Inc. v. Laidlaw Envtl. Servs. TOC Inc. 528 U.S. 167 180 2000. However an assignee who stands in the shoes of its assignors Spinedex Physical Therapy USA Inc. v. United Healthcare of Ariz. 2 Brown has failed to show that the Victa Letter was privileged and not subject to the crime fraud exception. See United States v. Ruehle 583...

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