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17 While surgical excision is the treatment of choice in the presence of moderate or severe OED, 10-35% of cases demonstrate recurrence post excision, particularly if there is dysplasia present at the excision margins or persistence of risk factors

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On the fiduciary breach claims, the district court followed the courts in Mehlberg and Bokma in finding plaintiffs had plausibly alleged the employer acted as a fiduciary with respect to assessing and collecting the tobacco surcharge and keeping the surcharge funds for its own benefit

The United States permits eight funded counseling sessions per attempt with no annual cap