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https://michiganlawreview.org/journal/unpublished-decisions-in-the-federal-courts-of-appeals/ "Downright Indifference": Examining Unpublished Decisions in the Federal Courts of Appeals -... the federal courts downright indifference examining unpublished https://repository.law.umich.edu/mlr/vol59/iss5/2/ "No-Strike Clauses in the Federal Courts" by Frank H. Stewart One consideration will support several promises. A promisor may extract more than one promise in return for his single undertaking to do - or not to do. 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