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Tom Cobb and Sarah Kaltsounis*
* © Tom Cobb and Sarah Kaltsounis 2008. Tom Cobb is a Senior Lecturer at the University of Washington School of Law. He clerked for the Hon. Susan M. Leeson of the Oregon Supreme Court from 2001 to 2003. Sarah Kaltsounis is a Lecturer at the University of Washington School of Law. She clerked for the Hon. Richard C. Tallman of the U.S. Court of Appeals for the Ninth Circuit from 2003 to 2004. We thank Kate O’Neill, Suzanne Rowe, Helen Anderson, Joel Ngugi, Mike Peters, and Deborah Maranville for reviewing earlier drafts of this article and making thoughtful comments, and we thank Mary Whisner for her superb research support.