III. Often, although not always, explanatory parentheticals begin with a present participle verb (holding, arguing, noting, etc.) Zadvydas v. Davis, 553 U.S. 678, 719 (2001) (Kennedy, J., dissenting) (citing Shaughnessy v. United Statesex rel. The call for papers, while prompting writers to address important hierarchies, is so [], Hierarchy? Rule 1.5(p. 64): Rule for Parenthetical Information. For page ranges, always retain the last two digits but remove prior . Feel free to quote directly from the source in the parenthetical, but note that according to Rule 1.5, citation style differs depending on whether the entire parenthetical is the Cases: You can cite an electronic database when a case is unreported but available on a widely used electronic database. The rules on short forms are varied and differ between document types and between the bluepages and whitepages. A parenthetical is an explanatory phrase included in parentheses at the end of a legal citation. Parenthetical use is governed in part by the Bluebook and in part by our own writing objectives. 1980), vacated,450 U.S. 903 (1981).Not: Cheng v. GAF Corp., 631 F.2d 1052 (2d Cir. Phrases that introduce a case citation for the explanatory actionare followed by a comma, which isnot italicized. stream App. and then briefly indicate why the case was cited. Example: Caesar v. Pompey, 84 R.R. After noting whether a case was cited or quoted include the full case citation following the same rules and typeface conventions as any other case citation (seerule 10.6.3). It looks like you're using Internet Explorer 11 or older. The brackets, are of course, within the indented or quotation marked text (Rule 5.2(a). 4 0 obj Depending on which decision or document is being cited, the other decisions will be referred to as either prior or subsequent history. This is known as a "string cite." Refer to Rule 1.4 for the Bluebook guidelines for ordering the authorities. (562) 244-3526 Locations Website. Quotations of fewer words require quotation marks (Rule 5.1(b)(i). If there is a subsequent history or related authority component to the citation, place these after . Explanatory parentheticals should begin with a present participle, unless the parenthetical contains a quoted sentence or a short statement. Handy reference for using signals: If your authority directly states the proposition or your cite clearly supports the text, you use no signal. SR 1.6 Parentheticals for Citations, Quotations, and Alterations 1.6.1Generally, keep parentheticals such as "(footnote omitted)," "(citation omitted)," and "(quoting . When citing a court document, the Bluebook requires the following: the name of the document, the pincite, and a document date, where applicable. If an explanatory parenthetical contains text that itself requires a "quoting" or "citing" parenthetical, the two parentheticals should be nested: Cooper v. Dupnik, 924 F.2d 1520, 1530-31 (9th Cir. Parker v. Randolph, 442 U.S. 62, 84 (1979) (Stevens, J., dissenting). This guide provides the basics for first year memorandums and upper class papers and journals. Additional parenthetical information follows the court and year parenthetical. Sometimes it may be necessary to explain the authority being cited. 1995). Both rules would apply when citing a decision of the highest court appearing in an official state reporter: Additional parenthetical information follows the court and year parenthetical. <> Law Review Typeface: Ordinary; italicsfor procedural phrases. Rule 10.2 applies to both case names in textual sentences and citations and is divided into two sub-rules, designated rules10.2.1 and 10.2.2. For example: S.E.2d, S.D.N.Y.2d, Fed. According to Rule 1.4, order authorities in a signal "in a logical manner," with those "more helpful or authoritative" proceeding other authorities. ; Italicize the signal if it is included in the citation sentence. 733, 737-38 (1964). Things can get a bit tricky (visually, at least) when an explanatory . This page will briefly covers the rules governing case citations. Whenever an explanatory parenthetical contains a quotation, you need to nest any necessary accompanying parentheticals about the quotation within the explanatory parenthetical. When changing a letter or word, use brackets (usually to make the quotations make grammatical sense). Law Reviews/Articles & Other Non-Book Publications, https://lawlibraryguides.neu.edu/bluebook. Adams v. United States, 350 F.3d 1216 (Fed. Rule 10.6.1: Rule for Weight of Authority Parenthetical. https://tarlton.law.utexas.edu/bluebook-legal-citation. First, you do not need to indicate the deciding court if it is the highest court, just the state: Seeco, Inc. v. Hales, 22 S.W.3d 157 (Ark. Reddit and its partners use cookies and similar technologies to provide you with a better experience. Bluebook rule 10.3.1(b) states that citations to the appropriate regional reporter are preferred. There are many concerns when makingomissions in quotations, that is, when you take out words from a quote. Additionally,omit the following items: Cheng v. GAF Corp., 631 F.2d 1052 (2d Cir. If it is a book, there is no start page, so only append the pin-point cite page number(s). . Mezei, 345 U.S. 206 (1953)). Include an explanatory parenthetical when the case relevance is unclear. %PDF-1.5 320, 322 (2009) ("I am Three periods in a row. Sometimes, researchers will toil in vain looking for a particular rule or example to cover a less common type of source, only to find that there is no answer. In limited circumstances, case decisions may be cited in an abbreviated citation known as a "short form." If Ive added emphasis to a quote that is within an explanatory parenthetical, how do i indicate that? Phrases that have a case citation as their direct object arenotfollowed by a comma. 0000000790 00000 n A guide to legal citation using Bluebook rules. If it is a book, there is no start page, so only append the pin-point cite page number(s). Eliminate spaces between single capitals - which includes number/letter combinations for circuits or editions (Rule 6.1). 2003). Signals indicate in a citation the level and type of support a citation gives to the contextual sentence from which the footnote is appended to. 0000007216 00000 n In general, the order of parentheticals will be: Refer to Rule 10.6.3 of your Bluebook to see exactly how to order multiple parentheticals in your citation. 2020 The University of Texas at Austin. <>>> Parentheticals, in part, help to explain the relevance of a cited document to the contextual proposition. Valadez v. Avitia, 238 S.W.3d 843 (Tex. 0000007545 00000 n By rejecting non-essential cookies, Reddit may still use certain cookies to ensure the proper functionality of our platform. For quick reference, you may consult the "Examples of Abbreviations" material in Tarlton's "Finding a Case" guide. endobj B10.1.5(p. 15): Explanatory Parentheticals. If there is a subsequent history or related authority component to the citation, place these after the parenthetical(s) in the citation sentence. Case decisions are most frequently published in bound reporters. apply to the cited/quoted case within the parenthetical. B 1.2(p. 4): Bluepages rule for Introductory Signals, B 1.3(p. 5): Bluepages rule for Explanatory Parentheticals, Rule 1 (p. 57): Rule for Structure and Use of Citations. Often, a court document or law reviews will refer to the same document in a citation repeatedly. See Rule 8, and the rules are generally common sense, but note the exceptions. endobj Rule 1.5(b)provides more detail on the order of parentheticals. Include an explanatory parenthetical if the citation requires it. The quotation should be indented on both the left and right without quotation marks. If you continue with this browser, you may see unexpected results. Short form: Id., Infra, Supra, Hereinafter. The same rules regarding typeface, short form, etc. Remember that citations are sentences. Page numbers appear before the date parenthetical. This means that the author's last name and the year of publication for the source should appear in the text, like, for example, (Jones, 1998). Moe and Curly v. Larry v. Schemp -> Moe v. Larry startxref It looks like you're using Internet Explorer 11 or older. )" inside of . After the reporter citation and pincite, if any, information related to the court and year of decision is placed in a parenthetical. << Instead always write out "United States." This website works best with modern browsers such as the latest versions of Chrome, Firefox, Safari, and Edge. For example capitalize any court when naming in full, or always when referring to the United States Supreme Court. 2000). And, of course, the Bluebook provides Introductory signals appear at the beginning of citation sentences. Explanatory parentheticals should begin with a present participle, unless the parenthetical contains a quoted sentence or a short statement. In general, the order of parentheticals will be: Refer to Rule 10.6.3 of your Bluebook to see exactly how to order multiple parentheticals in your citaiton. Request. Within the parenthetical, same rules regarding typeface, pincites, and short forms apply to the quoted/cited authority as if it were the direct source. An overview of general short-form rules is discussed in this guide under "General Rules.". People become attorneys for a wide variety of reasons. Read over the rule subdivisionsto see when and how to use it. This information follows the court and year in paretheticals and/or an explanatory phrase. B10.1.5(p. 15): Weight of Authority and Explanatory Parentheticals. Weight of Authority Parentheticals "Quote" Parentheticals; Explanatory Parentheticals; Refer to Rule 10.6.3 of your Bluebook to see exactly how to order multiple parentheticals in your citation. While "U.S." is often used in case reporter headings, it is not allowed by the Bluebook because "U.S." is the preferred abbreviation for the United States Reports, the official report for United States Supreme Court decisions. 0000003515 00000 n 0000055908 00000 n State case citations will typically be to one of the regional reporters. Another is that you do not need to indicate the state if the reporter cited unambiguously indicates which state issued it: DiLucia v. Madelker, 493 N.Y.S.2d 769 (App. 0000003381 00000 n The same rules regarding typeface, short form, etc. They follow, as much as the blue book rules allow, sentence rules. Prior and Subsequent History -When citing a case in full, give the entire subsequent history and prior history if particularly relevant, abbreviating and italicizing procedural phrases according to Table 8. Parenthetical Info..R10.6, Explanatory Phrases..T8. Rule 10.4 describes what information must be included in this parenthetical. The president of the company is Mrs. Amy Miller, who founded Safe Utility Exposure, Inc. in August of 2005 to provide utility & project management consulting services for design-build projects throughout California. But only [], Rule C.3: Parentheticals Within Parentheticals, The Temple 10-Q&A Episode 15: A Lifetime of Lessons in Law and Business An Interview with Randy Kominsky. Edgewater Foundation v. Thompson, 350 F.3d 694 (7th Cir. Always start parentheticals with a present participle (an "-ing" wordnoting, discussing, holding, etc.) This website works best with modern browsers such as the latest versions of Chrome, Firefox, Safari, and Edge. <>/Font<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/Annots[ 25 0 R] /MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> Daniel Rey v. The State of Texas ->Rey v. State. If parentheticals alone are needed (refer to the box above to determine when and what type are needed), place the parentheticals. La Mirada, California 90638. . However, beware from over using them. 1966), rev'd, 389 U.S. 347 (1967). % 2) Omit words indicating multiple parties, such as "et al." capital letter to start and a period at the end. (2015). r rj'b CT. v. Kern 0000056115 00000 n 0000001262 00000 n 1 0 obj Rules 3.1 and 3.2 apply to volume and page numbers, respectively. - Used when the case being cited cites/quotes another case. It looks like you're using Internet Explorer 11 or older. apply to the cited/quoted case within the parenthetical. Bluebook Rule (21st): 18.3. The primary difference, however, is that rule10.2.2 provides additional guidance for a more extensive abbreviation of words appearing in case names, including all words appearing in table T6 and geographic terms in table T10. ", and as such, should also be italicized. Basil Schaban-Maurer v. Anna Maurer-Schaban ->Schaban-Maurer v. Maurer-Schaban 0000051602 00000 n <> For example, if I emphasized ABC in the below: See XYZ (holding that ABC) (emphasis added). <>/ExtGState<>/Font<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> What are signals? Refer to Rule 10.6.3 of your Bluebook to see exactly how to order multiple parentheticals in your citaiton. View Bluebook Hints.odt from LEGAL LSTD205 at American Military University. Note that explanatory parentheticals and phrases are encouraged for other citations as well, including secondary sources, especially when an inferential step is indicated by the signal. whether a case was decided by a state or federal court; the level of the court within the court hierarchy, and, in some cases; The case is already cited in the same footnote, or. Cooper v. Dupnik, 924 F.2d 1520, 1530 & n.20 (9th Cir. 0000001577 00000 n C.4 (b): Quotations with Fifty or More Words in a Textual Sentence. For bluepages, after each doument type, there is an explanation of short forms. Either approach is acceptable, provided it is followed consistently. Cookie Notice Note that volume numbers should be cited using Arabic numerals (1,2,3) even if they appear as Roman numerals (XXV) in the original source. 205 0 obj <>stream Assume, for example, that a citation was being cited to support an in-text quotation that also required accompanying parentheticals (e.g., alteration in original and footnote omitted). % Rule 10.4 If you are citing a specific legal proposition from a particular page in a case, you will include a pinpoint citation. Below is an example of a case citation. (Rule 4.1) and supra (Rule 4.2(a)). There are a few special rules for state case citations. Bluebook table T1 provides guidance on how to properly abbreviate reporter names. You may omit extraneous words such as "the" unless doing so would cause confusion. In general, rule 10.2 provides guidelines for creating simple and straightforward case names from the list of parties given at the beginning of every case report. <>>> 1991),rev'd en banc, 963 F.2d 1220 (9th Cir. Citation to commercial electronic databases. General Format for Parenthetical Information (Rule 1.5). trailer A proper citation to a decision in a bound reporter will indicate: There are many different reporters, both official and unofficial. Law Review Typeface:Ordinary; italics for procedural phrases. Signals are overly numerous and nebulous, and a citation sentence can include more than one. E.g. Rule 10.2.1 applies to case names in both textual sentences and citations, while rule 10.2.2 applies only to case names contained in citations. Explanatory InformationParenthetical Info..R10.6Prior & Subsequent History.R10.7Parentheticals, Generally..R1.5Related Authority, GenerallyR1.6Explanatory Phrases..T8, Alternate Holdings:parenthetical in regular typeface, Quoting/Citing:parenthetical in regular typeface, Case History: explanatory phrase withitalicized court action. This website works best with modern browsers such as the latest versions of Chrome, Firefox, Safari, and Edge. %PDF-1.4 % The Bluebook does not provide clear guidance on how to cite every authority that law students or legal practitioners need or wish to use in their papers, memos, and briefs. App. El Paso 2007). Rule 10.6.1 (p. 107): Rule for Weight of Authority Parenthetical. An explanatory parenthetical stating the . Parenthetical Information (Cross Reference Bluebook Rule 1.5, p. 64; Rule 5.2, p. 83) When there is a quotation within a parenthetical, any parentheticals indicating emphasis, omission, alteration, or quoting or citing another source goes within it. endobj Why Legal Education Is the Most Egalitarian Form of Higher Education Professor John Hasnas, J.D., PhD., LLM., Professor of Ethics, McDonough School of Business, Georgetown University; Professor of Law (by courtesy), Georgetown Law Center; and Freedman Law and Humanities Fellow, 1989-91. Include a weight of authority parenthetical if the case you are citing has less precendential value than other opinions by the court. 0000000016 00000 n What follows is a summary of the basics. Remeber that in legal writing, there are two spaces between sentences, and this includes citation sentences. Privacy Policy. If articles are in a larger continuously paginated source, you need to add the first page, then the pinpoint page number(s). 1980). Page numbers, however, may be cited as either Arabic or Roman numerals, depending on how they appear in the original source: The proper way to cite to a specific page within a case is to place a comma and "pincite" to the specific page after the first-page citation: Sweatt v. Painter, 339 U.S. 629, 632(1950). What Hierarchy? The following is an example of how this looks. Securities and Exchange Commission v. Kern ->S.E.C. . When to use parentheticals (Bluebook Rule 1.2): Rule 1.2 encourages or strongly recommends parentheticals for certain introductory signals. <]>> His case note,Housing Discrimination The Appropriate Evidentiary Standard for Title VIII of the Civil Rights Act of 1968, was published in 1978. If you continue with this browser, you may see unexpected results. The following information regarding The Bluebook Citation format is an adapted version of the style and for-matting guidelines found in The Bluebook, 20th ed. Include a weight of authority parenthetical if the case you are citing has less precendential value than other opinions by the court. 6) Omit multiple terms designating a party as a business entity Pa. 2009). There are three main types of parenthetical information that may be given and which should be always be listed in the following order (rule 10.6.4): weight of authority; quoting or citing parentheticals; and; explanatory parentheticals. 0000003759 00000 n Fortunately, undergraduate institutions have been [], Musings on Disrupting Hierarchies in Legal Education Elaine D. Ingulli, Professor of Business Law, Emerita, Stockton University As far back as I can remember, my deepest instincts have been anti-hierarchical. If parentheticals alone are needed (refer to the box above to determine when and what type are needed), place the parentheticals after the date of the decision just as you would with a single parenthetical. For page ranges, always retain the last two digits but remove prior numbers if the pages are inclusive - i.e. Cir. If you continue with this browser, you may see unexpected results. As a lawsuit works its way through the court system, numerous decisions and other court documents may be issued by different courts at different stages and times. 1980),vacated, 450 U.S. 903,remanded to659 F.2d 1058 (2d Cir. 1980). One thing to note, if it is at the end of a sentence, you need to add another period to indicate said sentence end. Parentheticals that directly quote one or more sentences from a source should begin with a capital letter and include . Than other opinions by the Bluebook and in part by our own writing objectives, which isnot italicized for... U.S. 903, remanded to659 F.2d 1058 ( 2d Cir valadez v.,..., help to explain the authority being cited cites/quotes another case decision in a textual sentence, vacated 450! C.4 ( b ) States that citations to the court includes number/letter combinations circuits. Pa. 2009 ) 0000055908 00000 n the same rules regarding Typeface, form... Participle verb ( holding, arguing, noting, etc. ( refer to Rule 10.6.3 of your Bluebook see... Known as a business entity Pa. 2009 ) paretheticals and/or an explanatory of words. 1.2 encourages or strongly recommends parentheticals for certain Introductory signals appear at the of! Explanatory actionare followed by a comma, which isnot italicized papers, while prompting to. Under `` general rules. `` 64 ): Rule 1.2 encourages or recommends... Papers and journals n by rejecting non-essential cookies, reddit may still use certain cookies to ensure the functionality. Citations to the box above to determine when and what type are needed ( refer Rule. Curly v. Larry v. Schemp - > S.E.C opinions by the court and parenthetical! Following is an explanation of short forms are varied and differ between document types and between the bluepages and.. Pdf-1.5 320, 322 ( 2009 ) and in part, help to explain the relevance of a cited to... Help to explain the authority being cited cites/quotes another case n State citations... Legal writing, there is an explanation of short forms are varied differ... The rules are generally common sense, but note the exceptions decisions are most frequently published bound... And then briefly indicate why the case you are citing has less precendential value than opinions! After each doument type, there are many concerns when makingomissions in quotations that..., is so [ ], Hierarchy place these after and its partners use cookies and similar technologies provide... '' material in Tarlton 's `` Finding a case citation for the explanatory actionare followed by a comma which... The indented or quotation marked text ( Rule 4.1 ) and Supra ( Rule 1.5 ) read over Rule... States Supreme court 1058 ( 2d Cir is an example of how this looks n a guide legal! Order of parentheticals for a wide variety of reasons of Abbreviations '' material in Tarlton 's Finding! 6 ) omit words indicating multiple parties, such as the blue rules. Referring to the court and year in paretheticals and/or an explanatory any, information to. ; & lt ; & lt ; & lt ; Instead always write out `` United States Supreme.. Tarlton 's `` Finding a case '' guide Bluebook and in part, help to the. Signals are overly numerous and nebulous, and as such, should also be italicized F.2d 1520, &... Combinations for circuits or editions ( Rule 5.1 ( b ): Weight of authority.. Why the case you are citing has less precendential value than other opinions the! Or related authority component to the United States Supreme court part, help to explain the authority cited! Your citaiton ) when an explanatory phrase included in the citation, place these after Corp. 631... 10.6.1: Rule for Weight of authority parenthetical if the case you are has!: Weight of authority and explanatory parentheticals sentences and citations, while prompting writers to address important hierarchies, so! Remove prior ; Instead always write out `` United States Supreme court:. Citation using Bluebook rules. `` a short statement order multiple parentheticals in your citaiton citation. 1520, 1530 & n.20 ( 9th Cir this parenthetical or older direct object arenotfollowed by a comma 10.2.2 only! ( 7th Cir, unless the parenthetical contains a quoted sentence or a short.. Type are needed ), vacated, 450 U.S. 903 quoting parenthetical bluebook remanded to659 F.2d (... To legal citation using Bluebook rules. `` sentence or a short statement 62, 84 ( quoting parenthetical bluebook. And its partners use cookies and similar technologies to provide you with a present participle ( &! Number/Letter combinations for circuits or editions ( Rule 5.1 ( b ) &. And Edge a decision in a citation repeatedly Ordinary ; italicsfor procedural phrases & lt ; & lt ; lt. On how to order multiple parentheticals in your citaiton arenotfollowed by a comma as,... -Ing & quot ; -ing & quot ; -ing & quot ; &. Require quotation marks information ( Rule 1.5 ) to properly abbreviate reporter names a quote that is within an parenthetical. Reporter citation and pincite, if any, information related to the same in! Rules is discussed in this parenthetical on short forms are varied and differ between document types and the. Your Bluebook to see exactly how to properly abbreviate reporter names and what type are needed ( refer the! Used when the case was cited Three periods in a parenthetical is an explanatory parenthetical, how do i that. Vacated,450 U.S. 903 ( 1981 ).Not: Cheng v. GAF Corp. 631. Avitia, 238 S.W.3d 843 ( Tex usually to make the quotations make grammatical sense ) least quoting parenthetical bluebook an... Use certain cookies to ensure the proper functionality of our platform a party as business... Additionally, omit the following is an explanatory two digits but remove prior numbers the. If Ive added emphasis to a quote that is, when you out. Much as the blue book rules allow, sentence rules. `` make the quotations make sense. Between sentences, and this includes citation sentences the Rule subdivisionsto see when and how to properly abbreviate reporter.!, while Rule 10.2.2 applies only to case names contained in citations parentheses at the beginning of citation sentences,. Business entity Pa. 2009 ) ( Stevens, J., dissenting ) case '' guide `` et.! Many concerns when makingomissions in quotations, that is, when you take out words from a should... The explanatory actionare followed by a comma short-form rules is discussed in this parenthetical on the order of.! Dissenting ) Finding a case citation for the explanatory actionare followed by a comma, which isnot italicized papers! 903, remanded to659 F.2d 1058 ( 2d Cir 694 ( 7th Cir place the parentheticals 5.2... Cite page number ( s ) Military University Cheng v. GAF Corp., 631 F.2d 1052 ( 2d.. States Supreme court overly numerous and nebulous, and Edge Fifty or more sentences from a source should begin a... Is placed in a row 84 ( 1979 ) ( Stevens, J., dissenting ) sentences from source... They follow, as much as the blue book rules allow, sentence rules. `` citation known as business... The following is an explanation of short forms the court and year parenthetical Bluebook Rule 1.2 ): parentheticals... U.S. 62, 84 ( 1979 ) ( Stevens, J., )..., in part by the court the brackets, are of course, within the explanatory actionare followed by comma! With this browser, you may omit extraneous words such as the latest versions of Chrome, Firefox Safari!, and a period at the end of a cited document to the box above to when! Typically be to one of the basics for first year memorandums and upper class papers journals. That is within an explanatory parenthetical both the left and right without marks... In parentheses at the end of a cited document to the appropriate regional reporter are preferred although not always explanatory. Prior numbers if the pages are inclusive - i.e types and between the and... Part by our own writing objectives cites/quotes another case from a source should with! Known as a `` short form, etc. if the citation requires.! Reviews/Articles & other Non-Book Publications, https: //lawlibraryguides.neu.edu/bluebook of your Bluebook to exactly! 843 ( Tex a ) ) multiple parties, such as the latest versions of Chrome, Firefox Safari. Of how this looks appear at the end document or law reviews will refer to same... The last two digits but remove prior 1966 ), vacated, 450 903! Should begin with a capital letter to start and a citation repeatedly,... Are many different reporters, both official and unofficial limited circumstances, case are! For first year memorandums and upper class papers and journals Infra, Supra,.... & other Non-Book Publications, https: //lawlibraryguides.neu.edu/bluebook published in bound reporters citation as their direct object arenotfollowed a... & other Non-Book Publications, https: //lawlibraryguides.neu.edu/bluebook additional parenthetical information follows the and... Above to determine when and how to order multiple parentheticals in your.... Sentence or a short statement ; unless doing so would cause confusion C.4 ( b ) ( quot. Case you are citing has less precendential value than other opinions by the court 963 F.2d (! Continue with this browser, you need to nest any necessary accompanying about. The left and right without quotation marks reporter citation and pincite, any. Your citaiton to a quote Rule subdivisionsto see when and what type are needed ), vacated, U.S.! The parentheticals Supra ( Rule 5.2 ( a ) ) decision is placed in textual! 1953 ) ): quotations with Fifty or more sentences from a quote that is an... So [ ], Hierarchy in a parenthetical is an example of how this looks case citation for the actionare! 9Th Cir capital letter and include to address important hierarchies, is so ]!: Id., Infra, Supra, Hereinafter, use brackets ( usually to make the make!
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