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Andrew M. Carter*
* Associate Clinical Professor, Sandra Day O’Connor College of Law, Arizona State University. I thank Professors Jessica Clark and Amy Langenfeld for their labors editing this article. Their guidance was invaluable, and this article is surely better for their efforts. That said, any errors are mine alone. Finally, I owe a debt of gratitude both to the Sandra Day O’Connor College of Law for its generous support of this scholarship and to my colleagues within the Legal Method and Writing Program for their patience and good humor.