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In recent weeks, the U.S. Court of Appeals for the Second Circuit and the Appellate Division, Second Department, have decided numerous appeals in Long Island cases in which the parties have included State and county governments as well as Long Island towns, villages, boards and school districts, among other government entities. The claims in these appeals have ranged from inadequate training of employees in a �1983 action[1] and violation of the State Environmental Quality Review Act in a zoning dispute[2] to medical malpractice.[3] And, of course, a number of appeals have arisen in personal injury cases.[4]

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