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 Jonathan Corbett, Civil Rights Advocate

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Is It *Really* Impossible To Get A Gun License in NYC? (Part IV — An Appeal Amid Massive Corruption Scandal)

This is the fourth installment of a series documenting an ordinary New Yorker attempting to exercise his Second Amendment rights: Part I (license application), Part II (application rejected), Part III (the lawsuit).

 

After one hundred years of New Yorkers receiving gun licenses if and only if they gain the favor of the NYPD – often through cash payments – it is well past time for the courts of this state to step in and declare the NYPD’s implementation of the “proper cause” requirement to be unconstitutional…

gun-license-app-div-coverWe left off last fall with in Part III, where I filed suit against the NYPD for: 1) requiring that I provide them a “good reason” as to why I should be allowed to bear arms, 2) requiring that I answer entirely irrelevant questions (Have I ever been fired?  Have I ever been prescribed a prescription painkiller?), and 3) refusing to fulfill a public records request that would shed light on their supposed process for deciding on license applications.

After receiving service of the complaint, the NYPD filed a motion to dismiss, alleging that: 1) it’s totally constitutional to require a reason before allowing a citizen to exercise his or her rights, 2) that these questions are totally rational to ask of one seeking a gun license, and 3) that releasing records would “interfere with a law enforcement investigation.”  Judge Carol R. Edmead of the New York County Supreme Court granted this motion on February 7th, 2017, essentially rubber-stamping the NYPD’s arguments.  Judge Edmead required the NYPD to make no showing, for example, as to why they needed to know answers to any of their obviously irrelevant questions, and required the NYPD to present no evidence — not even a sworn declaration — that releasing records would cause legitimate interference with law enforcement.

The most glaring of Judge Edmead’s errors were in 2 parts:

  1. She conceded that gun restrictions must be subject to “intermediate scrutiny” — that is, they must address an “important” governmental objective by means “substantially” related to that.  She then went on to say that she was approving the NYPD’s actions because they were “rational.”  But a finding of “rationality” is not the test that she just stated was appropriate.  The NYPD’s tomfoolery must not be merely “rational” but be a substantially tight fit — asking not significantly more than is actually required to fulfill the “important” governmental objective of public safety.
  2. I’m actually somewhat shocked that she granted a motion to dismiss on the public records request given that, in deciding a motion to dismiss (the first opportunity a defendant has to get a case tossed out of court), a judge cannot yet weigh evidence because the plaintiff has not yet had a chance to present evidence.  Yet she had no problem finding that releasing the records would definitely interfere with a law enforcement investigation, just because an attorney for the NYPD said so.  In doing this, she cut off the case before allowing me a chance to argue the other side.

I immediately filed a notice of appeal, and today I “perfect” the appeal, as they say here in New York, by filing the “record” (a copy of everything that happened in the court below) and my appellate brief — given the requirement of 10 copies of everything (8 for the court and 2 for the opposing party), well over 2,000 pages had to be printed, bound, and delivered to make this happen (links to digital copies below).  In it, I detail for the New York Supreme Court, Appellate Division the history of corruption in the NYPD’s licensing division.  Some highlights from the last few decades, although the corruption goes back 100 years:

  • In 1973, NYPD Capt. Salvatore Salmieri was suspended for issuing a gun license to a mafia chauffer. Exhibit C – Narvaez, Alfonzo.  “Captain Suspended in Gun Authorization.”  New York Times (Nov. 17th, 1973).
  • In 1997, the head of the licensing division, Henry Krantz, was disciplined for, again, picking out individuals for whom the usual process did not apply: “Krantz was charged with providing ‘preferential treatment to individuals or entities,’ as well as ‘wrongfully directing’ other cops to grant the favors and failing to supervise his staff.” Exhibit D – Marzuli, John.  “Gun Licensing Boss Suspended by NYPD.”  Y. Daily News (Jan. 23rd, 1997).
  • In 2002, a former head of the licensing division, D.I. Benjamin Petrofsky, was accused of (and later demoted for) helping famous rock-and-roll musicians receive a pistol permit in exchange for VIP concert tickets and after-party admission.  Exhibit E – Messing, Philip.  “NYPD Under Fire in Aerosmith ‘Got a Gun’ Scandal.”  New York Post (Nov. 24th, 2002).  He allegedly went as far as to fingerprint the musicians inside Madison Square Garden.  Wiederhorn, Jon.  “Janie’s Got A Gun Permit? Aerosmith Flap Lands Cop in Hot Water.”  MTV (2002).

But of course, you’ve all probably heard of the more recent scandal that former U.S. Attorney Preet Bharara was investigating before Trump fired him:

According to court papers, the trading of gun licenses for bribes stretched from at least 2010 to 2016.  Exhibit H – Neumeister, Larry.  “Former NYC police, lawyer arrested in gun licensing probe.”  Associated Press (Apr. 25th, 2017).  In return for approval of gun licenses without meeting New York’s qualifications, D.I. Endall’s officers “solicited and accepted food, alcohol, parties, dancers and prostitutes.”  Id. Several of the gun licenses bought through the corrupt members of D.I. Endall’s office caught in this sting went to street vigilantes who were known for beating a man on the street so badly he is permanently blind in one eye.  In the meantime, the application by Corbett, who the NYPD concedes had no character issues, was denied.

Deputy Inspector Endall was, of course, the NYPD licensing division commander who denied my application not 3 weeks before being transferred to desk duty — err, lower desk duty — because several of his subordinates were arrested for literally taking hookers and cash for gun licenses.

I do hope the Appellate Division takes to heart that they are literally taking a blind eye to corruption if they do not take action.  From here, I expect it to take several months to get an opinion from them.  If it’s unfavorable, I can then ask the New York Court of Appeals, the highest court in the state, to hear the case, before moving onto the federal courts.

So “Is It *Really* Impossible To Get A Gun License in NYC?”  Not sure yet, but so far:

  • Money Spent: $1,365
  • Time Spent: ~80 hours

Will look forward to updating with Part V as the Appellate Division takes a stand.

Corbett v. City of New York IV – Appellate Brief (.pdf – 7MB)

Corbett v. City of New York IV – Record on Appeal (.pdf – 38MB)

UPDATE: Mere hours before I was to file this brief, the U.S. Court of Appeals for the D.C. Circuit invalidated D.C.’s “good reason” requirement for carrying firearms.  This is a major win, and so I updated my brief and re-printed it.  The above documents now reflect that change.


“Jon Corbett is a civil rights advocate known for filing the first lawsuit against the deployment of TSA nude body scanners, as well as defeating the body scanners live in ‘How to Get ANYTHING Through TSA Nude Body Scanners.’  Presently a law student, he continues to advocate for travel and privacy rights.  Twitter: @_JonCorbett, Web:https://professional-troublemaker.com/

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Insomniac Sued for Letting Overdose Victim Die: “Someone Has Died Every Year” at Insomniac Events Since 2006

Last year, I sued Insomniac, the producer of Electronic Daisy Carnival — a massive, 100,000+ attendee music festival held in the desert outside of Las Vegas, NV — over their policy of not allowing OTC medication into their event and requiring those with prescription medication to “consult” with a “safety officer” before they would be allowed in.  That case was settled before appeal after being dismissed on a technicality.

A large part of Insomniac’s argument in that case before settlement was that there was no need for attendees to bring in their own OTC medicines because they provide world-class medical services including all the medicine anyone could possibly need.  But, the reality is this: there are only 3 medical tents, and the Las Vegas Motor Speedway where the event is held is massive:

lvms

According to Google, the longest interior dimension is over 3,000 feet, or about 6/10ths of a mile (1 km).  To walk around the circumference of the venue would be about 1.5 miles (2 km).  With 3 medical tents, you’re looking at 1 tent every 1,000 or so feet.

At the 2016 festival, a young man named Nicholas Austin Tom succumbed to the heat in combination with MDMA intoxication.  MDMA (ecstasy, molly) is a common, relatively safe party drug with two main caveats: dehydration and hyperthermia (fever).  When you’re in a 110°F (43°C) desert, dancing and sweating, and do not consume water, you are already tempting fate with dehydration and hyperthermia, but add large doses of MDMA to that and the results can be deadly.

Of course, dehydration and hyperthermia are easy to treat in a medical setting: IV fluids and ice packs can save a life.  So, according to Mr. Tom’s attorneys, when he started seizing that evening, festival goers attempted to carry him to a medical tent — but it took them half an hour to find one.  Futher, when they arrived, there was no medical staff there, and by the time they returned, he was dead.

Did Insomniac just not know that they needed more medical staff?  From the complaint:

Beginning in 2006, someone has died every year at a rave put on by Defendants INSOMNIAC and [current parent company] LIVE NATION.

In case that seems like an exaggeration, they provided a list:

  • Joshua Johnson, 18 (Nocturnal Wonderland, 2006)
  • Michelle Lee, 21 (Monster Massive, 2007)
  • William On, 23 (Together as One, 2008)
  • Jesse Morales, 22 (EDC Dallas, 2010)
  • Sasha Rodriguez, 15 (EDC L.A., 2010)
  • Andrew Graf, 19 (EDC Dallas, 2011)
  • Kyle Haigis, 22 (EDC Dallas, 2011)
  • Emily McCaughan, 22 (EDC Vegas, 2012)
  • Arrel Cochon, 22 (Nocturnal Wonderland, 2013)
  • Anthony Anaya, 25 (EDC Vegas, 2014)
  • Brian Brockette, 20 (Electric Forest, 2014)
  • John Hoang Dinh Vo, 22 (Beyond Wonderland, 2015)

In fairness, it seems that they didn’t find a death for 2009, so perhaps for that year, they get a pass.

The bottom line: trying to take away people’s drugs at the gate doesn’t work.  Drugs will always be smuggled into music events.  What does work is providing adequate water and medical services.  Based on the list above, it would seem that Insomniac must know that they have a problem.  I just can’t fathom how Insomniac CEO Pasquale Rotella does not feel disgusted with himself for letting this happen.  (Feel free to let him know how you feel on Twitter.)

Tom v. Insomniac – Complaint (Los Angeles Superior Court, BC 665696) (.pdf)

* Provided with an F.U. to the Los Angeles Superior Court for charging me ~$15 just to retrieve that document, and to the media for reporting on the story but being too cheap or lazy to actually post the source document.  Public records should be free.

An Open Letter to Burning Man (and Law Enforcement): Locking Down a City to Find a Missing Teenager is Illegal

 

Trojan Horse, Burning Man 2011
Oh, a gift! Open the gates, let it in! [Art @ Burning Man, 2011]
Burning Man is a festival of art, music, culture, and spirituality, held annually in the vast deserts of Nevada.  Over 60,000 attendees gather and literally build a temporary city — roads, emergency services, a mail system, and structures of every shape and size — for one week.  Some of the most brilliant art projects in the world are showcased, many of which are ritualistically burned to the ground by the end of the event.

I find the experience I’ve encountered there to be like none other and treasure the learning and good times I’ve had.  But, the organizers of the festival consistently do one thing that, were they anyone whom I did not hold in such high esteem, would have been sued a long time ago: any time a “child” goes “missing,” they block the exits of the festival until found.  And almost invariably by “child” I mean “teenager,” while by “missing” I mean “has voluntarily gone off partying and some parent is worried.”

Open Letter to Burning Man
An Open Letter to Burning Man (.pdf)

This is literally the definition of false imprisonment.

Traditionally, at common law, false imprisonment is defined as the 1) confinement of another, 2) within fixed boundaries for any period of time, 3) who is aware of, or injured by, his or her confinement, 4) without consent or privilege (Nevada law takes a substantially similar view).  The “within fixed boundaries” part deserves clarity: the boundaries could be a cage, a house, a 100-acre estate, or even an entire city.  The “privilege” part also deserves clarity: there has never been a “privilege” to detain a single person without reasonable suspicion, let alone to detain 60,000 persons, 99.9% of which assuredly have no idea where the missing person is.

Cut that shit out.  It fails to uphold the community’s value placed on consent and self-reliance, and it’s just plain illegal.

U.S. Supreme Court Lifts Part of Travel Ban Injunction, Agrees to Hear Case

Travel Ban ProtestFirst: No, this was not a vindication of the “TRAVEL BAN.”

The U.S. Supreme Court today issued an opinion on the preliminary injunction entered by the 4th and 9th Circuits, as well as the government’s request that they hear the case (a “petition for certiorari” — that word is pronounced “sir-she-uh-ruh-ree,” for those wondering).  The tl;dr:

We grant the petitions for certiorari and grant the stay applications in part.

So, the Court will hear the case in the fall, but what part of the injunction did they put on hold?

The injunctions remain in place only with respect to parties similarly situated to [the plaintiffs].  In practical terms, this means that §2(c) [and §6(b)] may not be enforced against foreign nationals who have a credible claim of a bona fide relationship with a person or entity in the United States.

What it boils down to is this: the plaintiffs in this case were all alleging that they were denied access to attend to their family or business in the United States.  When you file a lawsuit, as a general rule, you can only ask the court to help you, not to right a wrong against the public.   Even if your case is a class-action, you can only seek to reach people “similarly situated” to you.

The lower courts enjoined the government from applying these two odious sections of the TRAVEL BAN to anyone.  But, since some people seeking entry have no connections to the U.S., those people are not similarly situated to these plaintiffs, and thus the Supreme Court narrowed the injunction to only those with some connection to U.S. persons or entities.

So, in summary:

  1. If you are accepted to university, are visiting a family member, or have been hired by a company in the U.S., the TRAVEL BAN is still on hold as to you.
  2. If you have no connection to the U.S. at all, you may have to wait a few months if you’re coming from one of the 6 Muslim countries Trump has banned — or get some family or business connections here first (the ruling isn’t quite clear if having “friends” to visit in the U.S. would count as a sufficient connection).
  3. In upholding the injunction as applied to those with a connection to the U.S., the Supreme Court is implying that the plaintiffs in this case are likely to win, because showing “likelihood of success on the merits” is required for any kind of injunction.  Good deal.

Terrorist Attacks Police Officer in Michigan Airport — What Could Have Prevented This?

Yesterday, it was reported that a Canadian national entered a Detroit-area airport, found a police officer, yelled “Allahu Ackbar!” and then repeatedly stabbed the police officer in the neck.

In the meantime, our government has focused on:

  1. A “TRAVEL BAN” (emphasis Trump’s).  But a ban on temporary visas for citizens of a half dozen Middle Eastern countries would not have excluded this Canadian Muslim terrorist (or any other terrorist, according to the U.S. Department of Homeland Security).
  2. A “laptop ban,” because older x-ray equipment can make it difficult to distinguish a laptop battery from a block of C-4.  The better solution being an upgrade of older x-ray equipment notwithstanding, every recent airport attack has either detonated a bomb before the security checkpoint or used an alternative weapon — like a knife.
  3. A more thorough molestation when going through TSA checkpoints.   Because despite all the other holes in TSA security, grabbing everyone’s genitals makes us feel safer, right?
  4. Surveillance — which, apparently, doesn’t work.

Here’s what our government has not focused on:

  1. Getting the hell out of the Middle East.  Instead, we’re still selling arms to Saudi Arabia and now bombing more civilians than ever.
  2. Fixing mental health in this country.  Scratch that, fixing health in this country.

There seems to be a simple solution: spend less on war, ineffective TSA security, and creating a police state, and spend more on healthcare.

So why aren’t we doing this?  Why don’t we, the people, the voters, insist on this?

Trump to Murderous Philippine President: “You Are a Good Man”

Some commenters on my blog have taken a bit of offense to my regular criticism of Donald Trump, going so far as to call me a “partisan.”  Shocked that after several years of railing against Obama administration policies (not to mention my pro-Second Amendment stance) that all of the sudden I’m now “partisan” for blasting Trump, it was explained to me that while I regularly complained of things that Obama’s agencies did, I rarely called out Obama personally.

I don’t consider myself a member of either political party.  The reason for any disparity in naming Trump personally more than Obama is two-fold:

  1. Obama had a filter and let his administration do their jobs, while Trump is a loud-mouth who puts his personal name on every bad decision his government makes.
  2. Some of the stuff Trump says, and does, is not just disagreeable, but is flatly ignorant.

For an example of the latter, yesterday, it was reported that in a phone call with the President of the Philippines, Rodrigo Duterte, our President said the following: “I just wanted to congratulate you because I am hearing of the unbelievable job on the drug problem. … Many countries have the problem, we have a problem, but what a great job you are doing and I just wanted to call and tell you that.”

If you’re unfamiliar with the situation in the Philippines at the moment, this may not sound so bad.  In that case, allow me to summarize their drug policy: President Duterte has directed his citizens to murder drug dealers and addicts in the street.  I mean this literally and with no exaggeration.  Some quotes:

  • “Go ahead and kill them yourself as getting their parents to do it would be too painful.”
  • “The funeral parlors will be packed. … I’ll supply the dead bodies.”
  • “Hitler massacred three million Jews. Now, there is three million drug addicts. I’d be happy to slaughter them.”

The country’ federal police, at last count, had reported killing 1,959 alleged drug dealers and addicts, and have additionally reported finding the bodies of 3,658 more killed by vigilantes.  That is over 5,000 people killed during this man’s term as president without a trial or any due process whatsoever, for a crime as small as possessing a few grams of meth.

But that’s not all.  Mr. Duterte admitted that, back when he was only a mayor, he used to personally kill people he thought were criminals in the streets.  “And [I would] go around Davao with a motorcycle, with a big bike around and I would just patrol the streets and looking for trouble also. I was really looking for an encounter so I could kill.”  In a level of hypocrisy fit for a king, that same article discusses Duterte’s addiction to fentanyl, a synthetic opioid many times more powerful than heroin.

Don’t really feel sympathy for druggies?  Fine, here are some other choice quotes:

  • On rape: “I was mad she was raped but she was so beautiful. I thought, the mayor should have been first.”  (Much like Trump’s response to his “grab her by the pussy” comment, Duterte responded to criticism by saying it is “just how men talk.”)
  • On traffic caused by a visit from the Pope: “Pope, son of a whore, go home. Do not visit us again.”
  • On Hitler: “At least Germany had Hitler.”

Now, after reading the above, let it sink in that our President said to Duterte, “You are a good man.”

Fuck you, Donald Trump.  Mr. Duterte is scum: a self-admitted murderer who does not believe in the rule of law and, quite simply, has respect for no one.  This is not a “good man,” and you are ignorant for saying it.

If that makes me a “partisan,” so be it.

Turkish President Orders Body Guards to Beat Up American Protesters In DC: This Is Why We Don’t Allow Thugs Into the White House

fuck_erdoganWith all of the scandals going on in D.C. surrounding the President, it can be hard to focus on a few people being assaulted.  But the 9 people injured, one seriously, near the White House in a brawl started by Turkish President Recep Tayyip Erdoğan deserves attention for two reasons.

First, Erdoğan is a thug and should not have been invited to the White House.  He is well-known for arresting and beating up protesters in his own country.  He is well-known for misogyny, stating that women are not equal to men and their role in society is “motherhood.”  And he is well-known for media censorship, not just in his own country, but going so far as to sue in a German court against a man who published a satirical poem disfavorable to him (poem below!).  You would think given that, when he was in the political minority, he was imprisoned for reciting a poem of his own, he would have aspired not to do the same, but I digress.  This is not who we should be hosting, as he does not share the value common to those who enjoy living in a free society.

Second, a recently released analysis of video of the brawl shows that Erdoğan himself ordered the assault.  His personal bodyguard can be heard to say, “he says attack,” immediately after speaking with Erdoğan.  His guards than rush to violence against a small group of protesters, allegedly from a political party that Erdoğan cutely labels “terrorists.”

Think about that for a second: a foreign head-of-state just ordered an attack on Americans on American soil.

We can’t prosecute these men because they have diplomatic immunity, but we can certainly expel the Turkish Ambassador, as Sen. John McCain has suggested (note that I don’t join in Sen. McCain’s depiction of Turkey as a “third world” country).  That would be a good start.  The State Department is investigating.

And, you know, not inviting thugs to the White House.

 

Defamation Poem, by Jan Böhmermann (translated)

Stupid as fuck, cowardly and uptight,
Is Erdogan, the president,
His gob smells of bad döner,
Even a pig’s fart smells better,
He’s the man who hits girls,
While wearing a rubber mask,
But goat-fucking he likes the best,
And having minorities repressed,

Kicking Kurds,
Beating Christians,
While watching kiddie porn,
And even at night, instead of sleep,
It’s time for fellatio with a hundred sheep,

Yep, Erdogan is definitely
The president with a tiny dick,
Every Turk will tell you all,
The stupid fool has wrinkly balls,
From Ankara to Istanbul,
They all know the man is gay,
Perverted, louse-infested, a zoophile,
Recep Fritzl Priklopil

Head as empty as his balls,
Of every gang-bang party he’s the star,
Till his cock burns when he has a piss,
That’s Recep Erdogan,
The Turkish president.

U.S. Customs Initiates New Officers Using “Rape Table”

The younger generation is fond of the phrase, “I can’t even,” to describe situations that are beyond the scope of normalcy.

U.S Customs & Border Patrol agents an Newark-Liberty International Airport, a stone’s throw from Manhattan, have been accused of initiating new officers — male and female — with a “hazing ritual” that they call the “rape table.”  A new officer subject to the “rape table” is led into a secure room where the lights are turned off and they are held down and groped and humped by their senior officers.

These are the people we’re supposed to be ok with searching our digital items without a warrant.  Who can detain you for up to 8 hours without giving you a reason, a phone call, or an attorney.  The people who are supposed to be busy, you know, keeping our borders secure.  Who also think the “rape table” is ok.

I.  Can’t.  Even.

How the California Bar Actually Grades the First Year Law Students’ Exam

fylsx-real-gradingI’ve made a few posts discussing California’s First Year Law Students’ Exam (the “FYLSX”), noting that I failed my first attempt by a fraction of a percent when the Bar applied a grading formula different from that which was advertised, and then, using the knowledge gained of their altered grading scheme, passed on my second try so spectacularly that the Bar published one of my essays as an example of how to write their exam.  I also briefly mentioned that I — as I’m known to do — filed suit to ask a judge to effectively require them to grade like they say they will and be more transparent about the exam and how they grade it.

The particular dispute was that they advertised that the multiple-choice section and the essay section of the exam would be “converted to the same 400-point scale” in order to “give[] these sections equal weight.”  When I received my score report from the first exam, I noticed that the scaling formula used by the bar resulted in it being impossible to score more than about 362 points even if every question was answered correctly, and likewise, it was possible to score far more than 400 points on the essays.

The attorney for the Bar assigned to the case disclosed additional documents, formerly considered to be secret and until now never disclosed to law students, to me yesterday that all but flatly admit that not only were the sections not weighted equally, but they also didn’t use a 400-point scale!  See if you can follow this tortured grading system they describe, because it took me several reads to figure it out:

Multiple-choice raw scores (i.e., number of items answered correctly) were equated to the June 1998, 2011, and October 2013 exams using 21 items that were common to each of these exams.  The equating formula was as follows:

Multiple Choice Scale = (3.4092 x raw multiple-choice score) + 21.6267

The candidates’ raw total essay scores were scaled to a score distribution that had the same mean and standard deviation as their multiple choice scores using the following formula:

Essay Scale = (2.3536 x raw essay total score) + -442.389

A candidate’s total score was the sum of that candidates’ multiple choice and essay scores.

What I gather from this is that 21 of the 100 multiple choice questions were repeats of previous years, and based on how well students did on those 21 questions, their grade on the entire 100 questions was curved.  Then, they calculated the average multiple choice score and the standard deviation, and curved the essay scores such that the average student gets the same score on that section as the multiple choice, and the score distribution was normalized to the same standard deviation.

From this it is clear:

  1. This has nothing to do with a 400-point scale per section.  The number 400 does not even appear in this internal document regarding their grading scheme.  The scale is created simply by comparing this group’s scores to previous scores and trying to curve it accordingly.  You’ll notice that if you plug in “100” as your raw multiple-choice score (a perfect 100 out of 100 questions) into the formula provided, the maximum score attainable is 362.5467.  Not 400.
  2. The sections do not have “equal weight.”  Saying that the average test taker got the same score on both their multiple-choice and their essay questions is not the same thing as saying “half your grade comes from multiple-choice, and half from the essays.”  Whether the essays count more or less than the multiple-choice section depends entirely on how well the other students do on their exams.  This is not equality, it is normalization.

So, for those taking the June 2017 exam, know this: on both exams I sat for, the essays counted far more than the multiple-choice.  You should therefore be spending far more time studying how to write a good essay than how to select A, B, C, or D correctly, unless your multiple-choice practice exams are turning out abysmally (for more study tips, see my previous post).  Hopefully by the October 2017 exam, a judge will have “persuaded” them to abandon this system.

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