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The research team, led by Kevin Davis, an economist with the independent research institute RTI International, found estimated trafficking rates to be similarly high in several other northeastern cities, including New York (about 48 percent), Providence (30 to 55 percent), and Washington, D.C

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Hung, J., Lam, J

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District Court for the Eastern District of Virginias ruling in the Performance Group case was more thorough in its analysis, but its reasoning was no less concerning, as it effectively transformed every plan administrator into a fiduciary with respect to all of its actions, regardless of whether the actions involve discretion