What Drives Volokh? (Update x3)

When Eugene Volokh took up the pro bono cause of Crystal Cox, whose insane rantings and accusations bought her $2.5 million in judgments for having smeared Kevin Padrick and Obsidian Finance, it was believed to be a principled stand.  Ken White described it best:

So it shouldn’t be any surprise that we protect the free speech rights of the disturbed and vengeful blogger Crystal Cox, even though she abuses the legal system in an effort to censor and retaliate against people for criticizing her.

That’s how we roll.

And the 9th Circuit agreed, reversing the judgment and holding that anyone, not just bloggers as has been widely misreported, who publishes publicly, without regard to whether they are mainstream media or, well, Crystal Cox, is entitled to a jury charge requiring a finding of negligence, at minimum, before she could be held to account.  A big win for speech, courtesy of Eugene.

But there was a belief that when Volokh got into bed with Cox, it was for the issue, not because of anything else.  Yet, a motion was filed that calls this into question.  On Cox’s behalf, Eugene seeks to amend the 9th Circuit’s opinion:

Appellant Crystal Cox does not ask this Court to modify the substance of its opinion. She does, however, respectfully request that the Court amend its opinion to withhold the sentence that now says,

Cox apparently has a history of making similar allegations and seeking payoffs in exchange for retraction. See David Carr, When Truth Survives Free Speech, N.Y. Times, Dec. 11, 2011, at B1.

As he notes, this sentence is of no consequence to the holding, the principle at stake. Rather, it’s a matter of hurt feelings, that Cox doesn’t like what the court wrote about her.  The sentence impugns her dignity and motives, at least from Cox’s perspective.

The point raised by Eugene, that citation to a New York Times article does not prove the point, has some validity.

A judicial assertion of misconduct by a named person, even a judicial assertion modified with the word “apparently,” could be based on the record in a case, or on authoritative findings by another court. But it ought not be based on a newspaper column, which was written without the benefit of cross-examination, sworn testimony, or the other safeguards of the judicial process. The claims in the columnist’s assertion are neither facts found by a factfinder nor facts subject to judicial notice under Fed. R. Evid. 201.

Of course, the motion presents a potential flaw that neither Cox nor Eugene may appreciate.  While Carr’s article may fall short of irrefutable proof, that doesn’t mean there aren’t a ton of other sources to substantiate the point with overwhelming evidence.

After all, Crystal Cox is not, her protestations to the contrary, a blogger like us.  If Eugene wants more and better support, he may get it. In spades. The rule of thumb is never ask a question when you don’t already know the answer. Eugene asks whether the evidence supports this sentence in the hope of the court saying, “meh, it wasn’t necessary anyway. Whatever.”  That may not be quite the way it goes when the prevailing party takes a swipe at the winning opinion.

But all that aside, why?  Why is Eugene Volokh still representing Cox? He’s made his point, won the principle, and had his moment of glory.  Yet, he still takes her phone calls. Why?

There are four possibilities that immediately come to mind:

1.  Despite Eugene’s pro bono principled involvement in the case, he feels a sense of duty to serve her personal interests, independent of the cause upon which his involvement was grounded.

2.  He just likes Crystal Cox and wants to make her happy.

3.  He thinks the sentence taints his victory and wants to beat the horse to death.

4.  Crystal Cox has done, or has threatened to do, something to coerce Eugene to continue to serve her personal interests even after the principled position has prevailed.

Which, if any, of these possibilities drives Eugene to make this motion? Beats me, but inquiring minds want to know.

Update:  Marc Randazza has submitted an Amicus Curiae Motion to the 9th Circuit with regard to Eugene’s challenge to a newspaper story as the foundation for the sentence. Ask, and you shall receive.  Citations are set forth under the argument heading, “Cox is an extortionist,” and this time, they don’t cite to a newspaper article.

Update 2:  Eugene has submitted opposition to Randazza’s amicus curiae motion, arguing that the authorities provided by Randazza should not be given preclusive effect.  Randazza, in turn, has replied to the opposition, noting that Cox “doth protest too much.”

Since the sources support the Court’s determination, the Court should make note of them, and should give Cox what she asked for: More authoritative sources for the proposition that she has “a history of making similar allegations [of wrongdoing] and seeking payoffs in exchange for retraction.”

Mind you, this is all to erase or support one sentence, prefaced by the word “apparently.”

Update 3:  Obsidian has moved for rehearing en banc of the decision.  This, obviously, is clearly within Eugene’s representation.  I also hear that there is an additional amicus filed (or to be filed?) with regard to the motion to strike the offending sentence by another “victim.”

58 thoughts on “What Drives Volokh? (Update x3)

  1. Aaron Williamson

    It’s not unreasonable for Volokh to believe that his ethical obligation (formally or informally) to advocate for his client did not end with the publication of the opinion. After all, while a lawyer might take a case for the issue, his responsibility is to his client. His rationale here is the same that a criminal defense attorney would offer if the judge slipped in, “while the defendant may have a defense here, incidentally, I also read a newspaper article about some other stuff he’s supposed to have done, and it looks like he has a history of armed robbery.” Volokh’s right — the issue wasn’t tried and the court even slightly misconstrued the article it relies upon. Will he wake sleeping dogs by asking the court to modify the opinion? I’d like to think a 9th Circuit judge would be above that sort of petty retribution, but maybe I’m wrong.

    1. SHG Post author

      “Not unreasonable” is an interesting way to put it. Eugene’s representation concluded with the 9th Circuit’s reversal, if that was his choice. He’s not precluded from doing more, but he’s not obligated either. It’s now his personal choice. The offending sentence is entirely tangential to the opinion, and he won. His representation does not extend to sentences which hurt her feelings, and your analogy to a criminal defense attorney is inapt. This is a defamation suit, not a criminal prosecution, and everything about it, from hints at propensity to burden, are different.

      True, she wasn’t tried for it, but then the court didn’t convict her of it either. Conviction is a very different thing than a line in an opinion that hurts your feelings. And as for waking sleeping dogs and petty retribution, perhaps you’re looking at this backward and while she is entitled to the proper negligence charge, she is not entitled to insulation from other wrongful conduct. Karma is a bitch.

      1. Turk

        I hate to speak for Volokh, but I have to think he disagrees with you that his job was done with the reversal. He likely sees his job a bit more broadly — and that includes any motions to reargue or anything else regarding the decision — and doesn’t see his job as done yet given the pot shot that was taken at his client. It isn’t like Cox can make the motion on her own to amend the decision; she’s repped by counsel and only he can do it.

        You gave 4 choices, and Occam’s Razor points the answer as #1.

        1. SHG Post author

          Then he would be wrong, if he thought he was obligated to pursue a motion to strike a sentence that was of no legal consequence other than hurt feelings. There is no actionable claim here. Eugene obtained the relief requested in full, and there is no motion to reargue (or anything else regarding the decision, aside from the sentence that hurts Cox’s feelings).

          So while it’s possible that Eugene harbors this mistaken belief, it would hardly fall under Occam’s Razor as one of the known facts is that Eugene isn’t stupid.

          As an aside, your characterization of the sentence as a “pot shot” is a curious. As was seen when Cox registered domains in the name of Randazza’s wife and child, then offered her reputation management services to keep his family from harm, this is hardly a pot shot. That was some nasty stuff going on.

          1. Turk

            It is possible that his retainer agreement has broad language in it about taking care of all issues before the 9th Circ. And that would be important to do when you have a client you want to keep away from the courthouse. Speculation on my part, but it feels reasonable.

            As to the “pot shot,” I say that because it had no bearing on the issue of how the trial court should have charged the jury regarding the standard to use in determining defamation ( “As he notes, this sentence is of no consequence to the holding…”)

            1. SHG Post author

              It’s possible. It’s possible his retainer requires him to wash her car. But even if it did, this would still be volitional. It’s like getting a not guilty verdict and demanding the jury be polled because juror number 7 gave the defendant a dirty look. As for it being a “pot shot,” whether it was gratuitous (notice the different word carrying different connotations) or not is up to the author of the opinion. It would seem that it played a role in their decision or it wouldn’t be there. Indeed, it’s role may have been that even if she is an extortionist (as Gloria Wolk suggests), she is still entitled to First Amendment protections. That’s not a bad thing, even if it would have benefitted from a better cite.

        2. G Thompson

          Pot shot??

          If Eugene thinks that was a pot shot in any way shape or form I have a feeling his due diligence in relation to the wide array of very substantial evidence in favour of this ‘pot shot’ is very lacking.

          Though I would suspect that he knows it was based on highly probable evidence and just wants for some other reason to remove the obiter reference . That other reason would be very much more likely based on Crystal’s highly IMHO (and others) narcissistic butthurt (for want of a better phrase) specially when she is currently trying to sue David Carr and anyone else who has the audacity to even contemplate the merest common sense thought that she is and absolutely was extorting people for her own gain.

          Maybe something should be written about her again on other blawgs, blogs, papers et. al. since I am positive she is trying to expunge any reference to factually damaging statements. … challenge accepted

  2. Gloria Wolk

    IMHO the 9th circuit’s ruling is much stronger for the First Amendment because they acknowledge the possibility that Crystal Cox is disreputable in other respects. The objectionable sentence means she does not lose First Amendment protection because of other, possibly related misdeeds. Thus, they pay homage to the First Amendment.

    Personally, I find it distasteful that Volokh continues to do the bidding of Crystal Cox, for any reason. It is logical to presume his agreement with her was to pursue the First Amendment issue–period. Once he won that, he should bow out. There are far more worthwhile First Amendment causes and people who need pro bono assistance, people who are victims of SLAPP suits.

    1. Randazza

      Exactly. I made that same argument on page 3 of the amicus brief.

      when this Court noted Cox’s extortionate behavior in its opinion, it sent the signal that even criminals deserve First Amendment rights – thus dispelling the usual truism that “bad facts make bad law.

      In cases where the most objectionable parties and speech find First Amendment
      protection, our constitutional commitment to free speech is more strongly
      reaffirmed. See, e.g., U.S. v. Alvarez, 132 S. Ct. 2537, 2550 (2012) (defendant
      lying about earning military honors); U.S. v. Stevens, 559 U.S. 460 (2010) (finding
      statute outlawing the production of “crush videos” and other animal cruelty
      unconstitutional); Nat’l Socialist Party of Am. v. Village of Skokie, 432 U.S. 43
      (1977) (allowing American Nazi party to conduct a march); Brandenburgh v. Ohio,
      395 U.S. 444 (1969) (overturning conviction of Ku Klux Klan leader based on his
      espousal of group beliefs). The factual context of this case is important. In the
      future, this case may very well be cited by legitimate bloggers in their defense. If
      the legal principles in this case provide some shelter, even to an extortionist, then
      legitimate bloggers will find greater protection under it. Accordingly,
      strengthening the factual analysis in this case may not fit Cox’s agenda of
      extortion, but it will increase the case’s precedential strength overall.

  3. Anderson

    Scott, unless there’s some sort of limited-representation agreement (and maybe not even then), a lawyer doesn’t get to tell the client “well I’ll represent you to the extent it serves my own interests.” If I represent Cox in a case, and she thinks a court opinion says something unnecessary and injurious to her, then I have a duty to represent her on that.

    I don’t know why you find this puzzling. Would you treat your own client differently?

    1. SHG Post author

      I think I’ve pretty well explained why. Eugene’s obligation is fully satisfied by his having obtained the full relief sought. It is not his responsibility to now go back and manicure the opinion to address sentences Cox doesn’t like. He is not precluded from doing so, but he is not obliged to do so either.

      More importantly, you seem to lack a firm understanding of the role of lawyer and client in determining what, if any, issues need to be addressed and how to do so. The client retains all decision making authority as to the ultimate goal. The lawyer is charged with tactical decisions, such as this. Many lawyers find this deeply confusing, thinking that the client gets to call all the shots, and the lawyer is obligated to do as the client commands. They are not.

      As for whether I would treat my own client differently, that’s like victims asking if we would defend a murderer if it was our child. It’s neither a thoughtful question nor rationale.

      1. Michael Winger

        I don’t think the line between goals and tactics is quite so clear. For instance, whether a criminal defendant testifies in his or her defense is a tactical issue, isn’t it? But a lawyer can’t forbid the client to testify. The lawyer can withdraw (and may be obliged to do so if the client is going to commit perjury), but that’s kind of the nuclear option, probably not justifiable absent perjury.

        1. SHG Post author

          A defendant has a constitutional right to testify. It’s a bit different. On the other hand, if a client demands that the lawyer call his mother as a witness, the lawyer can refuse.

      2. Anderson

        Sorry, I think the “your client” question is entirely appropriate: apparently, the case is over when you say it’s over? Not how things work in the Mississippi Bar. We have duties to our clients.

        1. SHG Post author

          I see that I’ve been terribly unclear today, as you failed to understand anything at all in my reply. My apologies.

          Yes. You have duties in Mississippi. Lawyers everywhere have duties. What they are is the question. Just saying the word “duties” doesn’t do much of anything to help illuminate that point. Even if you say the word three times and stamp your feet, it doesn’t help.

        2. Defcon

          Did you see this?

          Damn, that kid is dumber than dirt. It never ceases to amaze me that stupid people never get that they’re stupid. Dunning-Kruger is an amazing thing.

          1. SHG Post author

            Yes, I saw it, as is obvious since I wrote a rather lengthy comment trying to explain the concept. He responded like a child. Maybe someday he will understand. Not today.

            1. Defcon

              Is there a way some kid would know if you deleted 7 comments from this thread? The kid says that you did, I guess to suggest that you are censoring comments, though obviously you have posted comments from people who disagree with you.

              So is that accurate, is he just lying through his teeth now?

            2. SHG Post author

              I can’t imagine any way that someone would know (other than the person whose comment was trashed) whether or how many comments I delete. That said, no, I didn’t delete 7 comments from this thread, so apparently he’s either grossly mistaken (which would be shocking, of course), seriously confused or lying. Which one is irrelevant.

              As I’ve told some others who emailed me about him, he refuses to learn, reacted as one would expect of a three year old and isn’t worth any more of my time or attention. He’s one of the many non-entities on the internet who try to get the attention of grownups by stamping their feet. It’s of no consequence. Move along.

            3. SHG Post author

              I don’t take it seriously, even if he is being less than truthful. He’s butthurt, and when children are butthurt, they lash out. Having people lash out at you happens to blawgers. The only regret is that I had hoped to help him to understand the issue and failed. That was my failure, not his, as he can’t be expected to be more than he is.

            4. Defcon

              Maybe, but he still behaves like a little douche. You’re being very gracious toward him, here and there. He’s done nothing to deserve it.

  4. WJ

    Apologies, I don’t understand how you are so certain that Volokh’s obligation to represent Cox ended with the issuance of the 9th Circuit opinion. Wouldn’t it depend on the precise wording of the agreement limiting his representation of her (which I assume exists)? If that agreement said he would represent her until the 9th Circuit opinon “became final” or “was issued in final form” or some such, wouldn’t he then have an obligation to continue taking (reasonable) directions from Cox until the window for a petition for rehearing expired?

    1. SHG Post author

      No. Once he obtained all requested relief, that’s that. While he would be obliged to defend his win if the other side moved for rehearing en banc, that’s a fundamentally different element of representation. This just isn’t the same thing by any stretch of the imagination.

        1. SHG Post author

          And this motion has what, exactly, to do with the issuance of the mandate?

          As I’ve already said, if challenged by motion for rehearing, that’s a different issue. But if there is no motion for rehearing or to stay the mandate, then the mandate “must issue.” You know this, of course.

          This motion has nothing to do with anything other than it hurts the client’s feelings that it’s in there. This is completely tangential to the relief, as Eugene expressly states (not that there could be any view otherwise), has no legal consequence whatsoever and is purely gratuitous.

  5. SPD

    I would also hate to speak for professor volokh, but I’m not sure this decision isn’t tactical and in line with his independent interests. There DOES remain the possibility that opposing party will request en banc. Imagine representing this nut job. You have two options: comply with her request in the most reasonable way possible, or she will make a deranged, ranting, disrespectful motion herself. And antagonize the 9th Circuit. I sure wouldn’t want to risk letting Cox loose in my important appellate case.

    1. SHG Post author

      If the other side seeks en banc rehearing, that’s different, and if I were Eugene, I surely wouldn’t want my client ruining this decision. And left to her own devices, she most assuredly would.

      Actually, that may be the best explanation yet. If he didn’t make the motion, she would pro se, and who knows what havoc could follow.

      1. CrazyTrain

        In which case, would he have a duty to file something to protect the decision and the client’s interests? The mind reels . . .

        1. SHG Post author

          Protecting the win is one thing, going to the core of the representation. Tangential motions that have no bearing on the relief is a choice, much like inviting your client to spend the night at your house.

  6. Marc Randazza

    That would be my guess: She told him to file something or she would fire him and file something pro se. He then calculates “she fires me, files a batshit crazy pro se motion, the other party responds, and my decision comes unraveled…. or, I file this and maybe she shuts up long enough that this can finally be over and I am outta here.”

    Just my guess.

    1. SHG Post author

      There was a reason why Eugene bought up eugenevolokhsucks.com before taking on her case. It was a smart move.

  7. Pattern_Juggled

    (standard caveat re neither condoning nor not-condoning the extant party’s behaviour, &c.)

    Activist litigants often seek more than – or something different from – a mere “win” in a technical sense.

    The precise wording of a judicial finding can be, to use, as important as the structural foundations on which it rests. Lawyers, and substantively invested laypersons, may well care more for the legal principles applied and, naturally, it is those principals which are most likely to impact future litigation regarding the matter in question.

    However… in the court of public opinion – the big game, where wars of framing and context are fought and won – it’s that language that may prove more important than the deeper issues, or even whether one won or lost on a given matter. Kennedy’s language in Lawrence v. Texas, in that regard, is (nearly) as important as the overturning of Scalia’s beloved anti-gay statutes itself. It’s the language that fires the passion of other activists – or funding sources, or volunteers, or journalists… and so forth.

    Which is to say: as an activist litigant, one may well have a deep interest in the precise phrasing of a judicial finding – an interest atypical for a litigant seeking simply to win a given case. And, a lawyer representing such a litigant does her a disservice if he fails to both understand and respect that interest; whether he actively seeks to further such interest, or not, does of course remain up to him. I doubt it’s subject to formal Bar rules, at least as I understand them and in the jurisdictions with which I have a tiny bit of firshand experience. Irrespective, I’d ask – not demand, or compel… but ask – counsel to do the same, if a ruling came down in our favour, but included in it language that I felt could be (and surely would be) used by political opponents in the future.

    There’s litigation as a battle to win or lose, and litigation as a battle for control over the narrative itself. In the latter case, counsel becomes a component of the PR effort – good or bad – and can reasonably be asked to aid in that, in that grey zone where formal legal ruling shade into documents of public opinion.

    Not every lawyer is going to have an interest in this sort of meta-struggle, and fair enough. But for those who take on cases for clients with expressly that interest, it shouldn’t be unexpected that they take a somewhat broader view of the boundaries of their obligations and where those obligations find a bright-line ending.

    1. SHG Post author

      Nah. This ain’t no Lawrence v. Texas, and the sentence in issue is meaningless to anyone but Cox. And Cox is batshit crazy. You’re way off base here. Save it for a better opportunity to make a speech. You really picked the wrong case for this one.

  8. Defcon

    Are some of the people posting here insane? Volokh had no duty to file this bullshit motion. It’s total nonsense, and any practicing lawyer knows it. You file this for a client because you want to, whether because he’s a pain in the ass or you like him a lot, but it’s a totally meaningless, pointless, irrelevant motion and clearly beyond the scope of any obligation a lawyer has to a client on appeal.

    You people arguing that he had a duty to file any cockamamie piece of crap the client demands are either incompetent, nuts or have no clue what your responsibilities to a client are.

    1. CrazyTrain

      Agree with everything except that the motion, in the abstract, does have merit (though of course he had no ethical/professional duty to file it!). Appeals courts (and to a lesser extent trial courts) do include gratuitous BS that is unsupported in any event in a lot of opinions. The motion makes a good point about how courts really shouldn’t do that, especially when it is about an actual person (and I thought the point about laymen misunderstanding those gratuitous statements as having some official imprimatur because they are in a judicial opinion was a good one). Of course, as I said, the motion was merit “in the abstract.” Under the actual facts here, and as demonstrated by Randazza’s filing, the motion will probably only encourage these judges to put more gratuitous BS into their opinions. And I hope they do substitue the citations to better citations as Randazza requested.

      1. SHG Post author

        I agree that the motion has some merit, and that the court’s cite to a newspaper article was inadequate. Now that the motion has been made, and Randazza has befriended the court, perhaps this will all be cleared up.

  9. Jordan Rushie

    While I appreciate where Volkoh is coming from, I am also disappointed in him as a lawyer. I can’t believe he let Cox attack Randazza’s wife and daughter while representing Cox pro bono. Any trench lawyer knows this thing called “client control.” That’s where you say “Client, if you act like this, I am going to quit representing you.” In Volkoh’s case, he was a free lawyer. If you can’t control a client, you fire them. Imagine if a client stood up in court and starting cursing out a judge, or sending letters to opposing counsel. Would you continue to represent them at the expense of your own reputation? Hell no.

    Now it reflects even more poorly on Volkoh that after winning the case, he is trying to strike the important part of the opinion. Volkoh won the appeal. The end. At that point, his role as counsel was finished.

    At this point seems like the client is controlling Volkoh… not the other way around.

    1. SHG Post author

      You often surprise me with a more mature take than I would expect of you. Yes, it was very disappointing that Eugene remained as pro bono counsel for Cox while she was engaged in her bizarre attack on Randazza, and failed, for whatever reason, to control her. Deeply disappointing.

    2. G Thompson

      After Eugene publicly stated and then took the case on the basis of protecting every bodies (not just Cox’s) First Amendment rights I think he would be in a major bind by giving an ultimatum like what you suggested.

      He’s renown as representing people in these sorts of cases and it’s what he really does best and what he is absolutely driven by, though maybe in this instance it was a double edged sword. Dunno… maybe he really didn’t understand, or hasn’t dealt with the level of batshit craziness that Cox exudes towards everything she does. In this instance after the win Cox would more likely be fully empowered in her mind to demand everything she wants and seeing as how she actually treated Marc after his refusal BEFORE taking her case can you imagine what she would threaten towards Eugene and the other lawyers working with Eugene on this.. he’d have a duty to them too.

      This is purely hypothetical of course though based on her past histrionics I wouldn’t particularly want to be in Eugene’s position at the moment.

    3. Max Kennerly

      From a First Amendment rights’ perspective, the court’s dicta makes the case stronger, because it acknowledges the protections even in light of apparent repeated conduct. But Volokh isn’t an amicus on the case arguing solely for principle, he’s Cox’s lawyer. I don’t think he’s necessarily obligated to attempt to correct disputed dicta in the opinion, but it’s not crazy for him to think it’s within the scope of what he should do.

      Additionally, his role as appellate counsel is not “finished” until en banc and certiorari are resolved. That dicta could have an impact on whether en banc or certiorari are granted (and, if granted, the eventual decision), and so there are sound tactical reasons for him to dispute it now.

      1. SHG Post author

        Wow, a relatively thoughtful and informed comment. Way to go, Max! Honey, our little boy is growing up!!!

        If Eugene made the decision to pursue this motion in fear of this being raised in a motion to rehear or a cert petition (and yes, obviously they are part of his duties as appellate counsel, but I’m sure you understand the distinction and so I don’t need to lay it out in small words), that would provide an explanation. It wouldn’t be my tactical choice, for a variety of reasons, but at least it would be present a reasoned basis for the motion.

  10. Bruce Godfrey

    It’s dicta at worst, and who wants to irritate a conference room of federal appellate judges after a total win? Could such a motion tempt the bench into exercising any broader revisory power.

    As a trench lawyer, when you prevail, you get very polite and you leave rapidly with the client. Don’t tempt Zeus.

      1. Marc J. Randazza

        One time I was in court with a client, and got what we both thought was a resounding win. I was shocked that the judge had given us so much of what we asked for, and the judge seemed quite reluctant. But, after an uncomfortable silence, said “ok”

        The client leans over to me and says “hey, can you ask the judge…” I shusshed him and said “lets get the fuck out of here!” Frankly,

        To this day, the client laughs that I acted like we had just stolen something off the judge’s desk. And I explained to him that you should always act like that once you win. Take yes for an answer.

        1. SHG Post author

          That’s a fascinating story. Do you have more stories like that? Because, you know, I would love to hear them all. No, really.

          Yes, we have all had that moment when we found ourselves ahead of the game, and that’s when you say thanks, then shut up and walk out as quickly as possible before anything bad happens. And if you stick around long enough, bad things can and do happen on occasion, when you seize defeat from the jaws of victory.

  11. Jim Tyre

    On Update 3: No additional amici briefs, (or leave to file as amici) have been filed as of about one minute ago

  12. Pingback: Ask And Ye Shall Receive, Cox Edition | Simple Justice

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