On April 28th, the federal district court overseeing a class action securities fraud lawsuit against Washington Mutual, Inc. granted the motions submitted by former directors of WaMu and WaMu's auditor, Deloitte & Touche, seeking dismissal of the fraud and negligent misrepresentation claims asserted against them. The Court held plaintiffs failed to adequately allege justifiable reliance. "Plaintiffs only suggest that they read the Forms 10-K and Deloitte's certifications, without expressly alleging which documents they read, when they read them or how they impacted their decision to purchase or retain WaMu debt securities." The Court also dismissed the negligent misrepresentation claim against Deloitte because Deloitte did not owe plaintiffs a duty. In re Washington Mutual, Inc. Securities, Derivatives & ERISA Litigation.