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December 10, 2021


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Ah, but it is from Judge Selya. See U.S. v. Zannino, 895 F.2d 1, 17 (1st Cir. 1990). It gets quoted all the time in the First Circuit. Perhaps Judge Millett forgot to cite?

Steven Lubet

I should have known, even though Judge Millett cited only to herself.

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