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McDonald (P) was shot and injured by an unknown assailant in the parking lot of a Wal-Mart store. P sued Wal-Mart and Merrill Crossings (Ds) (the owner and developer of the shopping center) alleging failure to maintain reasonable security measures. P got the verdict with Wal-Mart seventy-five percent negligent and Merrill Crossings twenty-five percent negligent. Merrill Crossings recovered a judgment on its cross-claim for indemnity against Wal-Mart plus attorney's fees and costs. Wal-Mart appealed.

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