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Julie A. Oseid*
* Associate Professor, University of St. Thomas School of Law, Minneapolis, Minnesota. Thank you to my research assistants Jeff Wald and Christopher White. Mary Wells helped me locate several of the sources cited in this article. I am also very grateful for the assistance of my editors at Leg. Comm. & Rhetoric: J. ALWD: Melody R. Daily, Sara R. Benson, Joan Ames Magat, Ruth Anne Robbins, and Suzianne D. Painter-Thorne. This article is much improved because of their help.