Just over a year ago, an article in this column titled “Rulings of Trustee’s Duty to Diversify: What Have We Learned?“1 contained an examination of the lessons learned in the 25 years since the Court of Appeals decision in Matter of Janes2 by looking to its progeny—Matter of Rowe, Matter of Saxton, Matter of Dumont, Matter of Hyde, Matter of Creighton and Matter of Knox.3
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