The following excerpt is from Fraher v. Suryadevara, CASE NO. 1:06-cv-1120-AWI-MJS (E.D. Cal. 2011):
"Deliberate indifference is a high legal standard." Toguchi v. Chung, 391 F.3d 1051, 1060 (9th Cir. 2004). "[T]he deliberate indifference doctrine contains a heightened foreseeability requirement, this requirement differs from the traditional negligence foreseeability requirement only insofar as deliberate indifference requires the defendant
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