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White v. Jeppson, 2014 UT App 90 (April 24, 2014) 

Apr 24, 2014

Several investors sued their financial advisors for breach of fiduciary duty and violations of state securities laws. The district court granted the financial advisors’ motion and dismissed the claim for failure to join other financial advisors who were also involved, concluding that they were necessary and indispensable parties under Utah R. Civ. P. 19. The Court reversed, explaining that joint tortfeasors are not necessary or indispensable parties, and that it is not necessary to name them all in a single lawsuit if the plaintiff has not asserted claims against the unjoined parties.