Sofia tells her Accountant, Luca, to prepare the financial statements of her business and then send them to Chase Manhattan Bank. She tells Luca that she wants to get a loan for her struggling business. Luca prepares the statements and emails them to the Bank. Six months later, Sofia's business files for bankruptcy. Chase files suit against Luca because he prepared the financial statements negligently. He made Sofia's business look better than it really was. If Luca was negligent in preparing the statements, under which rule or rules can he be liable to Chase for negligence?