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23(c)(4), the Engle III court approved a bifurcated trial plan in which future courts would retain the jurys Phase I findings, other than those of fraud and intentional infliction of emotional distress, which involve highly individualized determinations, along with findings as to the entitlement to punitive damages, which succeeding juries would be left to determine

Wei L, Imanaka-Yoshida K, Wang L, Zhan S, Schneider MD, DeMayo FJ, et al

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