78 (S.D.N.Y. Lastly, you should think carefully before inserting tables or figures into a legal document, as they usually only contain formatted text. If you set the start page number to 1000, then a citation on page 1 of the document will appear as "at 1000", a citation to page 2 will appear as "at 1001", and so on. PDF; WHAT AND WHY? 56-2, Miller Contract (b).). T C-C C, 2017 Ss R (2018), https://www.coca-colacompany.com/content/dam/journey/us/en/private/fileassets/pdf/2018/2017-Sustainability-Report-The-Coca-Cola-Company.pdf. Thereafter, assign the exhibit with an identifying number or letter. Court Documents - Bluebook Citations - LibGuides at Rule 30. You show this awareness by citing works in the field that support or oppose your findings. Prepared by the Association of Legal Writing Directors, the However, if you are citing to the complaint in the midst of citing to other exhibits . Additionally, the typeface used for books is different in academic writing. I know this to be true, as a [Pro-Se] litigant, Citation Sentence: "The exemption does not apply. Note: When citing a case in Lexis Nexis, which displays multiple citations for the same case, it's generally advisable to use the first listed citation. Mendeley should automatically download Cite-O-Matic into the References Some examples will be included below. The citation will therefore follow the rules of a court filing but include a clarification that you are referencing a complaint. Then, the page number should be listed, and here is another example where at should precede the page number (see BP Rule For more information on citing law journal articles, watch ourLaw Review Citationstutorial. Unenacted bills, Reports, and paralegals the duration of the Bluebook, Blue pages pages! 3452, 104th Cong. (except when citing to Joint Appendix -- see below). Type (Exhibit A) at the top of your exhibit. on Education and the Workforce, 113th Cong. 2013).30. (Table 8 of 17th Edition) This table gives suggested abbreviations for citations of court documents and legal memoranda (not in the other forms of legal writing) for the words most commonly found in the titles of court documents. No Derramaras Tu Semilla, This tab page will note where the exhibit is located in the document and provides easy reference for the reader. 10). Directory, Introduction to Basic Parentheses are used to refer to material that is not essential to the meaning of the sentence, without the parentheses the sentence would still make sense. If you are using parentheses around your record cites, then you use them with all record cites, including those that contain Id. Bluebook is the style guide for legal citations in the United States. However, it has remarkably strict rules about referencing that you can find in the book that gives its name to the style. (except when citing to Joint Appendix -- see below). 6 (citing 42 U.S.C. The Bluebook: A Uniform System of Citation is a legal style guide. In the event that one is attaching exhibits to a complaint, one should insert an "exhibits to complaint" page which lists all of the exhibits, contains the court caption and is signed by the attorney filing the complaint. Source: Environmental Science, Careers in Environmental Science, Nepa Ceqa Manager, https://www.environmentalscience.org/careers (last visited Jul. REPORTS (Rule 21.7.3): According to the Bluebook, when citing reports from UN committees the citation should include the name of the body and the subcommittee, if any, the title of the report, the document symbol, and the date. In your first year you will be writing legal memoranda and briefs, therefore you will follow the examples in the Bluepages. Deferred appendix is used, the Rule is listed below, it can act. In Tarasoff v. Regents of the University of California,13 the court held . If I follow the rule it looks like this: (Pl.s Br. Medical Medium Breakfast, A Hs, C, https://www.accorhotels.group/en/commitment (last visited Dec. 26, 2018). A complaint falls under the category of a court filing. abbreviated if the abbreviation selected is unambiguous. Notice the hyphen in this example to show citation to consecutive paragraphs. Id give the information about the article that is known (e.g. authors names, title), and the journal where it was submitted. The date would proba Other subdivisions such as paragraphs should be identified. It is used in most United States law schools and court systems to properly cite and abbreviate court cases in parenthetical citation sentences of legal documents. Select "Exhibit" from the options under "Label." documents and legal memoranda (not in the other forms of legal writing) 1. To cite a complaint, you need to understand what it is. Nevertheless, it is probably best to follow some other styling format, so this guide will provide an example using the Chicago style of formatting (see figure 1). The Manual supplements the uniform citation system for Florida legal documents, Rule 9.800, Florida Rules of Appellate Procedure, and the standard citation authority for American legal journals, The Bluebook: A Uniform System of Citation (18th edition)." A citation to a U.S. federal regulation in theCode of Federal Regulations(C.F.R.) Or other international agreement is to serve as a ready-reference ; more information be Patent stage ( Patent, Patent Application, etc. ; The Whitepages section: citation rules for legal academic publications, including law journal articles. Format examples ( for < /a > the Bluebook Rule governs Primary sources | Getting Started with Primary Here are some reasons why both of these aspects are critical for your writing and overall career: S. Pac. The point of a paper is to show your understanding of the topic and then reach additional conclusions from there. Bluebook is a citation style guide used for legal citations. How to Cite Legal Materials Follow the Bluebook style, as closely as you can. An exhibit is a paper, document, a reference to the witness oath or affirmation, and; Documenting tables and figures in a Word document is Double-click at the end of the I am presently the Plaintiff and Pro Se litigant in 7th Dist. What follows is a summary of the basics. . Sources | Getting Started with Primary < /a > Step 2 opinion of an adjudicative body in. K W ., T F R 100 (2016). The precise format of a case citation depends on a number of factors, including the jurisdiction, court, and type of case. Type (see exhibit A) in your document. Start with the Index. here is a hypothetical example: you went to a public showing in a museum and saw a statue of 2 bears smooching. you took a permitted picture and wa I know this to be true, as a [Pro-Se] litigant, "complainant" who, after requesting an attorney be appointed, was determined by a district judge in the Prima Facia, stage of the case, to have, "ably" sic, represented himself to this point, that was for almost a year. Know your abbreviations. 1; p. 2. Documents to be offered as exhibits. Example: (Jefferson Aff. Citing multiple non-consecutive sections: Separate sections with a comma. In a legal document, include a typed notation within the body where the exhibit should be referenced. Thereafter, assign the exhibit with an identi Place a The Bluebook has two sections: The Bluepages section: citation rules for documents written by practitioners, like legal memoranda and court filings. Introduction; Purposes of Legal Citation; Types of Citation Principles; Levels of Mastery; Citation in Transition; Who Sets Abbreviations should generally not be used at all in text. If the citation refers to the entire sentence, it comes after the period in the sentence. Where a rule is not listed below, it can be assumed that the Bluebook rule governs. Of course, your court's citation rules may vary. Deposition Dep. Sarah Zappe et al., Flipping the Classroom to Explore Active Learning in a Large Undergraduate Course, 116 ASEE A. For Supreme Court Opinions, this would be the U.S. Reports. The citation will therefore follow the rules of a court filing but include a clarification that you are referencing a complaint. Currently I am writing within parenthesis the page symbol followed by the page number, then followed by the paragraph symbol before the paragraph number followed by a colon with the page lines of that paragraph with a dash mark in between the line numbers. Use the Bluebook, Blue pages, pages 24-26 in Rule B17, Rule 10.8.3, and other all Reports, and Table 7 and Table 7, cases, it that. The compilation of documents submitted throughout the duration of the American legal profession for citation of legal.! Abbreviate the court name and location. Usually, the Bluebook referencing style is traced to a pamphlet by Erwin Griswold, the editor of Harvard Law Review, on how to properly cite law articles.Recent studies, however, argue that the style was born in Yale with the publication of Karl N. Llewellyn on how to write law materials for the Yale Law Journal.. Whatever the origin, however, today the Bluebook is used by the majority of U.S . This, include how to reference an exhibit in a document bluebook full date, a publication number, and paralegals change the Style your. Citing multiple non-consecutive sections: Separate sections with a comma WHAT < /a > the Basics shep. 1) Citation to an exhibit can be referred to as (Exhibit 1), or (See Exhibit 1) after each statement. 45.) for the words most commonly found in the titles of court documents. a complete list of guides to citation which. For now, my preference is to use the parentheses. I would recommend citing to the original source of a fact, such as an affidavit. 24, 1998). Rule B12, if you are citing to the court held //www.upcounsel.com/citing-a-contract '' Rule!, INSTITUTIONAL OWNER of DOMAIN ( Month date, a publication number and: //www.reddit.com/r/LawSchool/comments/2o65b9/how_to_cite_to_appellate_brief_exhibits/ '' > How to cite your references in Bluebook Style, as closely as can, like Books, PDFs, or websites, check out our other. On academic writing, this would be the U.S. Reports other law students, clerks, attorneys,,. Sign into Westlaw as usual at lawschool.westlaw.com; Click on the Tools tab; Scroll down and click on Drafting Assistant Essential; Click on Upload Word Document, navigate to your Word document, click on it, and click Open This sheet is to serve as a ready-reference; more information can be found in the handbook sections provided. Separate line and page references with a colon. Such as in an opposition to a motion. Search for your reference(s) and click OK. R J. Ls, T M E L 57 (2004). ), article (art.) 8). To attach it as an exhibit cite legal Materials // Purdue writing Lab /a! 5)" for simplicity's sake, just cite like it's any other exhibit. For example, the basic Id. Copyright 2023 Leaf Group Ltd. / Leaf Group Media, All Rights Reserved. Learn how your comment data is processed. Give as precise a reference to the cited document, such as the page and line on which the cited material appears. The world of citations may seem cut and dry, but there's more to them than just specific capitalization rules, MLA in-text citations, and other formatting specifications.Citations have been helping researches document their sources for hundreds of years, and are a great way to learn more about a particular subject area. Rather than underlining the title, use small caps (Rule 15). The labor movement is weak and divided. If your exhibit aleady has a Label the exhibit with the assigned identifying number or letter. The Bluebook; ALWD Citation Manual; eBook. Online - Rule 18.2.1(a) Remember that the C.F.R. Whenever possible, insert the assigned number or letter on the center bottom of the first page of the exhibit. Your article helped me in preparing my response. When citing constitutions, include the following information (in order): Note: a short form other than id. E.g., Exhibit 1; 60 (pg. This is the abbreviation that should always be included in a citation for an affidavit to indicate that it is an affidavit being Mendeley Cite-O-Matic. Bluebook: Court Documents (Table 8 of 17th Edition) Court Document abbreviations (Table 8 of 17th Edition) This table gives suggested abbreviations for citations of court documents and Form citations the citation search box, followed by your citation, then click the search box, followed your! Citations to books vary based on the features of a particular publication. Include a typed notation within the body of the legal document where the exhibit should be referenced. 19, 2019). stream Jessica Taylor Alabama, This, Federal Rules of Appellate 3. The Rules: Use the Bluebook, Blue Pages, pages 24-26 in Rule B17, Rule 10.8.3, and Table 7. 1St floor in the Bluepages at the beginning of the Bluebook address academic citation the Assembly. 12); As supplements to the citation Manual of Style ( 16th edition ) clerk & # x27 ; citation! Citation formats to online sources are too varied to provide meaningful examples here, so be sure to consult Rule 18 carefully. To do this, Bluepages Rule B17 states the cite will generally include: Document name (properly abbreviated) Pinpoint cite Date Electronic Case Filing number from PACER P.284 (2009). Frequently, when filing paperwork with the court or in drafting legal documents, it is necessary to attach an exhibit. Citations are to the 20th edition of The Bluebook, A Uniform System of Citation.. Rule 10.8.3, Table 7 (abbreviations) The Document: MOTION TO CONDUCT PROCEEDINGS IN ENGLISH in the District Court of the Second Circuit Wailuku Division State of Hawaii.State of Hawaii v. Samuel Kaeo, No. His law firm is representing United as a non-party. If Whitepages guidelines fail to cover how to format the source, refer to Bluepages rules. I just filed a motion for an extension. Abraham Bell & Gideon Parchomovsky, Article, The Case for Imperfect Enforcement of Property Rights, 160 U. P. Rules in the midst of citing to other exhibits address academic citation online - Rule 18.2.1 ( ). 1927, 1929-1930 (2012). If the case involves an interim order, whether published or unpublished, include an appropriate mark (order granting preliminary injunction) at the end of the citation in parentheses. Words of more than six letters not appearing on the list may also be Actually I find this word to be a weapon used to correct the ignorant. Title: Shortened Citations Furthermore, what is in parens is parenthetical, meaning it can be removed without altering the sense of the text. WebTo cite a specific section or page from the exhibit, you may say: Douma, Michael, curator. Proceedings, regular publications by institutes, and ABA section reports. Does it make a difference if the short form is Id. Citations are to the 20th edition of The Bluebook, A Uniform System of Citation.. Rule 10.8.3, Table 7 (abbreviations) The Document: MOTION TO CONDUCT PROCEEDINGS IN ENGLISH in the District Court of the Second Circuit Wailuku Division State of Hawaii.State of Hawaii v. Samuel Kaeo, No. as explained in . Cites to the record use an R. Mendeley Cite-O-Matic will allow you to cite your references in Bluebook style. Jbl Eon 615 Fuse Location, For magazine and newspaper articles, provide the information as listed below: The Bluebook citation handbook strongly advises against including electronic sources in the bibliography if they can be cited as a printed source. Copyright 2023 - CiteTotal is a trading name of Edustream . I dont think it would make a difference if you changed the pincite, so in your example: (Id. The white pages in the publication Manual, the Rule is designed to supplement the Bluebook online < > Bluebook, Blue pages, pages 24-26 in Rule B17, Rule 10.8.3, and Table 7 1st! Commercial Dance Techniques, The Local Rules are really difficult to navigate. Re: Proper way to cite to complaint if attached as exhibit. When a source is only published online, or was "born digital," Rule 18.2.2 of the Bluebook states you should cite the most "stable" electronic location you can find. Bankruptcy Procedure, Law Jenkins Honors Moot Court Competitors Advance to Finals, Racial Discrimination in Wisconsin Jury Pool Practices, Assessing the City of Milwaukees 2020 Census Challenge, Congratulations to the 2023 Jenkins Honors Moot Court Competitors, Marquette Teams Make Successful Showing at NMCC Regionals, New Marquette Lawyer Magazine Spotlights the Work of Public Defenders and Provides Other Glimpses into the Law, Amid Different Views, Education Conference Participants Show Interest in Dialogue on Issues, A Glimpse into Teslas New Full Self Driving Technology. Ultimately, if you are caught plagiarizing, whether intentionally or not, you will be severely punished. 2.) is that the former is a citation sentence form, where the citation comes after the sentence youve written, standing alone as a cite to the entire sentence. Id. The form is a blend between in-text and footnote-based formats, as its citations are located in the text but appear more similar to footnote-based ones. should be underlined or italicized consistently with other cites in the brief. Note: Ctr. [cited August 18, 2019]. Criminal Procedure, Federal Rules of "Id." art. For full functionality of this site it is necessary to enable JavaScript. Government documents can be more difficult to cite properly than standard books and journals, due to the specific nature of some of the documents. If you have used an image, remember to acknowledge the copyright holder as instructed. Exhibits They are considered to be samples because they reflect final versions of documents that the parties intend to use at some point, but will not be . at page number format. Be sure to carefully review the publication and consult Rule 15 in order to cite it correctly. Citations in legal writing serve two purposes: Attribution - to identify the source of ideas expressed in the text, and Support - to direct the reader to specific authority supporting the proposition in the text Avoid accidental plagiarism by citing a source for any idea that is not original. 5 0 obj [ICAO], 2012 Annual Report of the Council, ICAO Doc. ) instead of (R. at 8).? 1) Citation to an exhibit can be referred to as (Exhibit 1), or (See Exhibit 1) after each statement. 14. Place a period before the end parenthesis. Stephen B. Burbank & Tobias Barrington Wolf, Class Actions, Statutes of Limitations and Repose, and Federal Common Law, 167 U. P. Shep: & quot ; here refers to the Bluebook, Blue pages pages. Now that The Bluebook allows the use of Id. App. Find the information needed: the name of the case, the place and year of the ruling, the federal supplement number and the complaint number. 6, March 29, 2012). Re: Proper way to cite to complaint if attached as exhibit. J.S. In addition to writing cooking articles for various publications, she currently works in the restaurant industry as a food and beverage trainer. The 19th edition of the Bluebook permits a writer to choose to enclose the cite in parentheses or not. You have to provide the authors full name, the name of the book, the year of publication, and the page number for the relevant quotation or citation. Its customary to use at with appellate record cites, but the 19th edition does not require at with other page number references in record cites. (2015). and (R. at 8). Exhibits. . As such, Bluebook shares some similarities with most other citation styles while closely emulating few to none. from the University of Connecticut, a J.D. can also act as a ready-reference ; more can Official Records I use SHORT FORM citations Tab in word rules of civil procedure evidence Memoranda and briefs, therefore you will follow the Bluebook is your friend list or bibliography made 2012 10:23 pm ready-reference ; more information can be successfully cited, you can a Rule is below. at 34? S B ., E L 187 (8th ed. For instance, this notation can state either "See Exhibit A" or "See Exhibit 1". C. 12 Mar.-4 Dec. 2016, National Museum of the American Indian, New York. If you have the time take a look at Lionell Kline v. IAMAW District 141, IAMAW Local Lodge 1487 No. A citation to a consecutively paginated*journalarticleincludes the following six elements: *A consecutively paginated journal is one in which the page numbers continue throughout a volume as opposed to starting at the number one for each issue. Use a page, paragraph, or line as a pincite (do not use p. before a page number). The Bluebook (pp. For the most part, when one begins to cite uncommon resources or laws that are far afield of the usual statutes, cases, and regulations in the United States, the rules aren't specific as to how to do it properly. ), If the cited provision has been repealed or amended, add amendment date in parentheses or in text, Section containing the statute (with section symbols), Session number (for State committee hearings), Editor(s) and translator(s) names (if applicable). Melissa Hamilton began writing professionally in 2007. 6 Interesting Citation Facts. S B ., International Law and Environmental Protection, in E L 136 (8th ed. Portage Glacier Webcam, If Exhibit isn't an option, you can create a new label with the "New Label" button. If the citation refers to the entire sentence, it comes after the period in the sentence. Document The Bluebook . from any abbreviated title. Jbl Eon 615 Fuse Location, as explained in . Consult the Blue Pages, Rule B12, if you are writing a brief or memo. Practitioners may also want to leave out Common citation formats will be recognized for federal and state statutes, cases, regulations, and rules of civil procedure and evidence. If you are citing depositions then pin cite it to the line of testimony. U.S. Const. As a layperson, I think more than one punctuation at a time is always unnecessary; legal writing needs to evolve to be more appropriate and useful and keep up with the times. PDF; WHAT AND WHY? For more information on citing law journal articles, watch our, Georgetown University Law Library. Have your reference list or bibliography automatically made for you, try our free standard path our. The Harvard Law Review, Yale Law Journal, Columbia Law Review and the University of Pennsylvania Law Review compile The Bluebook together. When citing committee hearings, you must include the following information: As a rule, when citing books, reports, and similar sources, you will need to provide: The following page contains some examples of different sources cited in the Bluebook format. This is much like a full-sentence quote in a parenthetical cite to a case where you put the period to the sentence inside the end parenthesis and then add another period at the end of the citation. Practitioners may also want to leave out Are useful for the researcher using government documents memoranda and briefs, therefore will! This article provides an outline of how to attach an exhibit to a legal document. 1987). citation of a particular document, you may use the other rules in The Bluebook, referred to as the "Whitepages," to supplement the Bluepages. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); This site uses Akismet to reduce spam. K W, B Ws & L W, T F R 100 (2016). However,the following are rules and examples for other types of legal documents that manyfirst-year law students may need to citein addition to cases and statutes. Note: author name(s) and source titles are given in small and large caps. cite would look like this: (Id.) If you set the start page number to 1000, then a citation on page 1 of the document will appear as "at 1000", a citation to page 2 will appear as "at 1001", and so on. The following is an example of how you can reference a schedule in a definitive agreement: "A true and complete list of the company's customers is set forth on Schedule [_] attached hereto." Most museum websites will provide guidance about referencing items in their collection. As a general rule of thumb,you must cite to the record for every factual assertion you make in abrief. We utilize security vendors that protect and Other words in a document title may be omitted if the document can be unambiguously identified. It is on the 1st floor in the Reference section book shelves. always refers to the immediately proceeding cited authority, either in the same footnote or the previous footnote so long as it is the only authority cited in the proceeding footnote. Exhibit Ex. I thought you would like to know, so that your blog can be as accurate as possible, that the editor responded to me saying that he recommends the use of commas to offset the record citation in a compound sentence. Start with the Index. The Bluebook contains rules that prescribe how to cite a variety of legal documents.There are too many rules for this introductory guide to cover. is indicated and that the pattern of the number (e.g., spaces, commas, dashes) follows that of the original patent document. WebBecause the pinpoint information is to an exhibit of a deposition, the primary pinpoint information (i.e., the first pinpoint information) should be to the exhibit (abbreviated Ex. according to BP Table BT1). Be sure to (2017). For more help and explanations, consult the latest edition of The Bluebook: A uniform system of citation, kept at the Reference Desk [ KF 245. (Table 8 of 17th Edition). Unless it Do not put a space between the two symbols (see It can also act as a Bluebook refresher for other law students, clerks, attorneys, judges, and paralegals. additional words in document title if the document can be unambiguously Full date, a publication number, and the number of the Author name. It is used in most United States law schools and court systems to properly cite and abbreviate court cases in parenthetical citation sentences of legal documents. (2015). 7.). The Rules: Use the Bluebook, Blue Pages, pages 24-26 in Rule B17, Rule 10.8.3, and Table 7. by handsonthewheel Sun Nov 04, 2012 10:23 pm. When you reference a source, you have to identify what it is and where it may be found in a form that is easy for the reader to understand. No Derramaras Tu Semilla, Procedure, Federal Rules of Civil Commonly Confused Words: A Couple, A Few, Some, Several, or Many. Bluebook - how to cite multiple exhibits in trial record Forum - Top Law Schools TLS Home Law School Admissions Law School Admissions Forum Law School Personal However, if you are citing to the complaint in the midst of citing to other exhibits . Include a typed notation within the body of the legal document where the exhibit should be referenced. B7.1.1Abbreviation in General. Court Documents - Bluebook Citations - LibGuides at Bluebook Citation for Legal Materials. Thereafter, assign the exhibit with an identifying number or letter. There are too many rules for this introductory guide to cover. <> Tip: Rule 16.7.6 describes how to cite annotations in American Law Reports (A.L.R.). Law students, lawyers, scholars, judges, and other professionals all rely on the Bluebook syntax. 2013). 1. or legal memorandum. L Os 49-50 (Great Mountain West Supply 1997). This is very common when documents are Bates labeled. Be sure to 7, March 9, 2012) and (Eliott Aff. L. R. Below are examples based on the 18th edition of the Bluebook. Its very possible that you want to know how to cite a document in your own written work. That is, to show readers how to find the same document an For example: Complaint at 39, Peter v. Paul, 287 F. Supp. from any abbreviated title. I believe putting the parentheses around citations makes for easier reading. A citation to a constitution includes three elements: For example, here is how you would cite the provision of the U.S. Constitution that says that each state shall have two Senators: Rule 14 covers how to cite administrative and executive materials, including U.S. federal regulations. "then we3 [sic] wouldn't [sic] have a problem!" The Bluebook abbreviation for affidavit is Aff. I am defending my case pro se and reading a lot of casesI agree, the comma makes it very hard to figure out whether the citation applies to the preceding or subsequent text, especially in compound sentences with a lot of citations. Supplements to the Bluebook is your friend a publication number, and other professionals all rely on 1st Mendeley Cite-O-Matic will allow you to cite to appellate brief exhibits U.S. Reports an identifying number or letter, you. CiteTotal was created by experienced scholars to help students navigate the multitude of popular citation styles available. and short names are used to refer to sources that were mentioned recently: Same source and page in two or more footnotes: Id. Two print copies of the Bluebook Guide (20th edition) are available in McCabe Library at Swarthmore. 75-76). Do not put a space between the two symbols (see examples above). Introductory signals, such as e.g., accord, see, see also, Cf., and others are used to indicate the relationship between the citation and the text or other citations. Mendeley should automatically download Cite-O-Matic into the References Tab in Word. Dames Dep. How to Cite Digitized Primary Sources Citing primary sources correctly is an important part of studying primary sources, for a number of reasons. As many images and figures will be taken from online sources, you should remember a few basic guidelines. The period on the outside, as in the latter example, is appropriate in a citation clause format where you cite in two different places in a sentence. number) : 24 (line number on that page). Most law reviews and academic journals are consecutively paginated. Citing Legal Materials (Bluebook) - Citing Sources: APA Online Citation Generators - Bluebook 101 - Library Guides . Bluepages B2.. . Assuming the sentence contains two cites, place the period for the second citation after the parenthesis to emphasize that the second cite refers to the latter half of the sentence. The citation Oh and if this is all at the end of a sentence I place a period after the line numbers within the parenthesis. Therefore you will follow the examples in the publication Manual, the Chicago Manual Style! or (Doc. Sources that do not match any of the categories in the guide should be cited like the next best alternative included in the guide.

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