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WESTERN DISTRICT CASE NOTES

This article originally appeared in The Bulletin, the official publication of the Bar Association of Erie County. It is reprinted here with permission. Standing and Fed. R. Civ. P. 23.1 In Cellino & Barnes, P.C. v. Cellino & Cellino, LLP, No. 19-cv-00729-EAW (Aug. 5, 2019), a shareholder in a professional corporation brought a derivative action against a ...

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