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Lisa Eichhorn*
* © Lisa Eichhorn 2008. Professor of Law, University of South Carolina. I would like to thank the University of South Carolina School of Law for funding my research on this project. I would also like to thank all of the Civil Procedure students I have taught over the last thirteen years at West Virginia University, the University of Denver, and the University of South Carolina for helping me refine my understanding of the Federal Rules of Civil Procedure.