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It was almost exactly one year ago on Nov. 28, 2008, when, in a horrifying moment, a Wal-Mart worker was trampled to death and customers injured on the Friday after Thanksgiving. This occurred after a crowd of approximately 2,000 shoppers burst through the front doors of a Wal-Mart store in Valley Stream in a race for a limited supply of advertised sale items. Investigations that followed made it clear that there was inadequate crowd management. This holiday season is an appropriate time to analyze the duty of care of those in control of the sites of mass gatherings to protect participants from the foreseeable dangers of overexcited crowds and acts of violence in those settings.

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