NOVEMBER/DECEMBER 2007

VOL. 79 | NO. 9

Journal
NEW YORK STATE BAR ASSOCIATION

“A Just Cause for War”

How slave transit in an abolitionist state Also in this Issue
sparked New York’s Dred Scott decision. Tax Deduction of
Settlements
by William H. Manz Lessons from the
Smithsonian
As a Client Faces
Loan Default
Did the Appellate Odds
Change in 2006?

Electronic copy available at: http://ssrn.com/abstract=1296646

THE LEGAL WRITER
BY GERALD LEBOVITS
GERALD LEBOVITS is a judge of the New York City Civil Court, Housing Part, in Manhattan and an
adjunct professor at St. John’s University School of Law. He thanks court attorney Alexandra Standish
for assisting in researching this column. Judge Lebovits’s e-mail address is GLebovits@aol.com.

Do’s, Don’ts, and Maybes: Legal

Writing Grammar — Part I

I
n four of the last five columns, the “books.” Add “es” if the noun ends in dren.” “Foot” becomes “feet.” “Goose”
Legal Writer discussed the things “s,” “sh,” “ch,” or “x.” “Dress” becomes becomes “geese.” “Man” becomes “men.”
you should and shouldn’t do in “dresses.” “Wish” becomes “wishes.” “Mouse” becomes “mice.” “Ox” becomes
legal writing. We continue with 10 “Church” becomes “churches.” “Fox” “oxen.” “Person” becomes “people.”
grammar issues and, in the next col- becomes “foxes.” “Tooth becomes “teeth.” “Woman”
umn, with 10 more. Studying these 20 If the noun ends in a “y” and a con- becomes “women.”
grammar issues offers a framework to sonant precedes the “y,” change the Some nouns stay the same whether
write comprehensible, intelligent doc- “y” to “i” and add “es.” “Baby” becomes they’re singular or plural. Example:
uments. Good grammar is a good start, “babies.” “Beauty” becomes “beauties.” “deer,” “fish,” “moose,” “Portuguese,”
although good legal writing demands If the noun ends in a “y” and a vowel “series,” “sheep,” and “species.”
much more. Knowing grammar won’t precedes the “y,” add an “s.” “Alley” Some words maintain their Latin or
make you a good legal writer. But becomes “alleys.” “Attorney” becomes Greek form in the plural. “Nucleus”
you’re a poor legal writer if you don’t “attorneys.” becomes “nuclei”; “syllabus” becomes
know grammar. Pluralize most nouns ending in “f” “syllabi” (“syllabuses” is accept-
Grammar is a system or set of rules by adding “s.” “Brief” becomes “briefs.” able); “focus” becomes “foci”; “fun-
that govern a language. English cat- “Proof” becomes “proofs. “Roof” becomes gus” becomes “fungi”; “cactus” becomes
egorizes words into eight different “roofs.” “Dwarf” becomes “dwarfs.” “cacti” (“cactuses” is acceptable); “the-
parts of speech according to how the Exception: Change some nouns end- sis” becomes “theses”; “crisis” becomes
words function in a sentence: nouns, ing in “f” or “fe” to “v” and add “es.” “crises”; “phenomenon” becomes “phe-
pronouns, verbs, adverbs, adjectives, “Elf” becomes “elves.” “Knife” becomes nomena”; “index” becomes “indices”
conjunctions, interjections, and prepo- “knives.” “Leaf” becomes “leaves.” (“indexes” is acceptable); “appendix”
sitions. Nouns refer to an event, idea, “Life” becomes “lives.” “Wolf” becomes becomes “appendices” (“appendixes”
person, place, quality, substance, or “wolves.” is acceptable); “criterion” becomes “cri-
thing. Pronouns are used in place of If a name ends in “f,” add an “s” to teria.”
a noun. Verbs name an action, occur- form the plural. “Mr. and Mrs. Wolf”
rence, or state of being. Adverbs mod- becomes “the Wolfs.”
ify verbs, adjectives, clauses, sentenc- To pluralize compound words,
A verbs must agree
es, and other adverbs. Adverbs don’t make the main word plural. “Attorney with its subject.
modify nouns. Adjectives modify general” becomes “Attorneys general.”
nouns or pronouns. A conjunction con- “Court-martial” becomes “courts-mar- If a noun ends in “ics” and refers
nects two words, phrases, or clauses. tial.” “Passerby” becomes “passersby.” to a body of knowledge, a science, or
An interjection shows strong emotion. “Sister-in-law” becomes “sisters-in course of study, it’s usually singular.
A preposition links to another word in law.” Two exceptions: (1) if the com- Examples: “mathematics,” “phonetics,”
the sentence a noun or a pronoun fol- pound word has no noun, add an and “semantics.” If a noun ends in “ics”
lowing the preposition. “s” to the end of the word; (2) if the and refers to concrete activities, prac-
Here are the most common gram- compound word ends in “ful,” add an tices, or phenomena, it’s usually plural.
mar errors — not the controversies; “s” at the end. Examples: “Dress-up” Examples: “athletics,” “mechanics,”
only the recognized, accepted errors becomes “dress-ups.” “Takeoff” becomes and “acoustics.” Sometimes whether
— and how to fix them. takeoffs.” “Teaspoonful” becomes “tea- nouns are singular or plural depends
1. Singular and plural nouns. For spoonfuls.” “Cupful” becomes “cup- on their meaning. Example: “Acoustics
most nouns, add “s” to form the plu- fuls.” is the study of sound.” (Singular.) Or:
ral. “Bat” becomes “bats.” “Window” Some nouns change when they
becomes “windows.” “Book” becomes become plural. “Child” becomes “chil- CONTINUED ON PAGE 74

80 | November/December 2007 | NYSBA Journal

Electronic copy available at: http://ssrn.com/abstract=1296646
THE LEGAL WRITER sentence makes sense if you say “They Incorrect: “Someone used their pen to
CONTINUED FROM PAGE 80 argued the motion.” Therefore: “He and deface the judge’s bench.” Becomes:
they argued the motion.” Incorrect: “Someone used his pen to deface the
“The courtroom’s acoustics (acoustical “Mary and me went to court.” In this judge’s bench.” To eliminate the sexist
qualities) are poor.” (Plural.) Example: example in which “Mary” replaces a language, change to “Someone used a
“Athletics (athletic training) isn’t pronoun, follow the same rule: Delete pen to deface the judge’s bench.”
part of law school.” (Singular.) Or: “Mary.” The sentence makes sense if The “one” exception: “Attorney
“Athletics (sports) are popular with you say “I went to court.” Therefore: Able is one of those jurists who knows
sports attorneys.” (Plural.) Example: “Mary and I went to court.” Incorrect: what he is doing.” Becomes: “Attorney
“Politics affects every aspect of our “The judge played softball with Henry Able is one of those jurists who know
lives.” (Singular.) Or: “His politics and I.” The sentence doesn’t make what they are doing.”
(opinions) aren’t going to affect our sense if you delete “Henry and.” The The “not one” exception: If “none”
decision.” (Plural.) sentence would be, incorrectly: “The means “no one” or “not one,” the verb
2. Pronouns. Pronouns substitute judge played softball with I.” Therefore: is singular. If “none” refers to more
for nouns. Some common singular “The judge played softball with Henry than one person or thing, the verb is
pronouns: “he,” “her,” “hers,” “him,” and me.” plural. Examples: “None of us [mean-
“his,” “I,” “it,” “me,” “mine,” “my,” Never use these nonstandard reflex- ing not one of us] knows grammar.”
and “she.” Some common plural pro- ive and intensive pronouns: “their- “None of the attorneys know how to
nouns: “its,” “our,” “ours,” “their,” self,” “theirselves,” “themself,” and write the brief.”
“theirs,” “them,” “they,” “us,” and “themselfs.” A “pair” of exceptions: “A pair of
“we.” Some pronouns stay the same Pronouns must agree with their socks” but “three pairs of socks.”
whether they’re singular or plural: antecedents in gender, person, and “Both,” “few,” “many,” “others,”
“you,” “your,” and “yours.” number. An antecedent is the noun to and “several” are always plural.
“All,” “any,” “more,” “most,”
“none,” and “some” are singular or
Legal writers will object to you plural depending on the noun or pro-
noun to which they refer. Incorrect: “All
fusing participles. the attorneys eats lunch at Forlini.”
Becomes: “All the attorneys eat lunch at
Forlini.” Incorrect: “All the pizza in the
Use reflexive and intensive pro- which the pronoun refers. Example of judge’s chambers are gone.” Becomes:
nouns only to refer back to a pronoun. a singular antecedent with a singular “All the pizza in the judge’s chambers
Some common reflexive and inten- pronoun: “Jane [singular antecedent] is gone.”
sive pronouns: “myself,” “yourself,” alleges that XYZ Corp. violated her Collective nouns in American usage
“yourselves,” “ourselves,” “herself,” [singular, feminine pronoun] consti- take a singular verb. Some common
“himself,” “themselves,” and “itself.” tutional rights.” Example of a plu- collective nouns: “appellate court,”
Examples: “I said that to myself.” ral antecedent with a plural pronoun: “army,” “assembly,” “audience,”
(Reflexive pronoun.) “I myself said “Mary and Jane [plural antecedent] “board,” “committee,” “couple,”
that.” (Intensive pronoun.) Incorrect: allege that XYZ Corp. violated their “crowd,” “family,” “jury,” “major-
“The judge and me [or myself] went [plural pronoun] rights.” ity,” “number,” and “team.” Incorrect:
to the courtroom.” It’s not “me [or Indefinite pronouns don’t refer to “The jury was right. They decided cor-
myself] went to the courtroom.” It’s “I any specific person or thing. Here are rectly.” Becomes: “The jury was right.
went to the courtroom.” Therefore: “The some common indefinite pronouns: It decided correctly.” Or: “The jurors
judge and I went to the courtroom.” “all,” “any,” “anyone,” “anybody,” were right. They decided correctly.”
Here’s a tip when you write a sen- “anything,” “each,” “either,” “every- Incorrect: “The family won the case.
tence with two or more pronouns: one,” “everybody,” “everything,” They celebrated.” Becomes: “The family
Delete the first pronoun. Then ask “little,” “much,” “neither,” “nobody,” won the case. It celebrated.”
whether the sentence reads with an “no one,” “none,” “nothing,” “other,” “We” versus “us.” To determine
“I,” “me,” “he,” “him,” “she,” “her,” “one,” “somebody,” “someone,” and when to use the pronouns “we” or
“they,” or “them.” Incorrect: “She and “something.” These indefinite pro- “us,” drop the noun or noun phrase
him went to court.” Delete “she.” The nouns are always singular. Incorrect: before the pronoun. Incorrect: “Us
sentence makes sense if you say “He “Everyone has their price.” Becomes: attorneys can no longer tolerate the
went to court.” Therefore: “She and he “Everyone has his price.” To eliminate firm’s policies.” If you drop the noun
went to court.” Incorrect: “He and them the sexist language, rewrite the sen- “attorneys,” the sentence wouldn’t
argued the motion.” Delete “he.” The tence. Correct: “Everyone has a price.” make sense: “Us can no longer toler-

74 | November/December 2007 | NYSBA Journal

ate the firm’s policies.” Correct: “We The writer did not mean to write, exam if she had studied harder.” “The
attorneys can no longer tolerate the “The judge feared the Constitution.” suspect acted as if he were guilty.”
firm’s policies.” If you drop the noun Becomes: “The judge feared that the “The judge requested Mrs. Doe’s pres-
“attorneys,” the sentence makes sense: Constitution would become a shield ence at the hearing.”
“We can no longer tolerate the firm’s for lawlessness.” Or: “The judge feared 5. Irregular verbs. For most verbs,
policies.” Incorrect: “The firm has given the Constitution’s becoming a shield form the past tense by adding a “d”
we paralegals no alternative.” If you for lawlessness.” or “ed” at the end of the verb. “Talk”
drop the noun “paralegals,” the sen- 4. Verb Tenses and Moods. Verbs becomes “talked.” “Play” becomes
tence wouldn’t make sense: “The firm have six tenses: present, past, future, “played.” Other verbs are irregular.
has given we no alternative.” Correct: present perfect, past perfect, and future Irregular verbs change a vowel and
“The firm has given us paralegals no perfect. The last three tenses (pres- add “n” or “en”; change a vowel and
alternative.” If you drop the noun, the ent perfect, past perfect, and future add “d” or “t”; or don’t change at all.
sentence now makes sense: “The firm perfect) are also known as the past To form the past participle, use a
has given us no alternative.” participle form. The present refers to helping verb: “is,” “are,” was,” or “has
3. Fused Participles. Fused parti- actions occurring when the writer is been.” Then add the principal part of
ciples occur when a writer fails to use writing. The past refers to actions that the verb.
a possessive form of a noun or pro- occurred before the writer wrote. The Examples: “Arise” (present tense)
noun to introduce a gerund. Use logic future refers to actions that will occur becomes “arose” (past tense) becomes
to solve fused-participle problems after the writer writes. The present “arisen” (past participle). “Bear”
by eliminating miscues. Ask yourself perfect refers to actions that began in becomes “bore” becomes “born” or
where the reference and stress should the past and were completed before “borne.” “Beat” becomes “beat”
be. Incorrect: “The People objected to the present. Use the past perfect when becomes “beaten.” “Become” becomes
the defendant leaving the courtroom one past action was completed before “became” becomes “become.” “Begin”
a free man.” The gerund “leaving” another past action began. Use the becomes “began” becomes “begun.”
is fused into the noun “defendant.” future perfect when an action that “Bite” becomes “bit” becomes “bit-
“Leaving” is the object of the preposi- started in the past will end at a certain ten.” “Blow” becomes “blew” becomes
tion “to”; “leaving” doesn’t modify the time in the future. “blown.” “Break” becomes “broke”
noun “defendant.” In this sentence, the An example of the verb “talk” using becomes “broken.” “Choose” becomes
reader might incorrectly believe that the different tenses: “talk” (present); “chose” becomes “chosen.” “Come”
the People objected to the defendant. “talked” (past); “will talk” (future); becomes “came” becomes “come.” “Do”
Therefore: “The People objected to the “have talked” (present perfect); “had becomes “did” becomes “done.” “Draw”
notion that the defendant would leave talked” (past perfect); and “will have becomes “drew” becomes “drawn.”
the courtroom a free man.” Or insert talked” (future perfect). “Drink” becomes “drank” becomes
an apostrophe: “The People objected to Form the present perfect by using “drunk.” “Drive” becomes “drove”
the defendant’s leaving the courtroom “have” or “has” before the past parti- becomes “driven.” “Eat” becomes “ate”
a free man.” ciple. Form the past perfect by adding becomes “eaten.” “Fall” becomes “fell”
Fused participles affect pronouns. “had” before the past participle. Form becomes “fallen.” “Fly” becomes “flew”
Incorrect: “Do you mind us getting all the future perfect by adding “will becomes “flown.” “Forget” becomes “for-
these cases?” In this example, the writ- have” before the past participle. got” becomes “forgotten.” “Forgive”
er didn’t mean to write “Do you mind Three moods exist in English: indic- becomes “forgave” becomes “forgiven.”
us?” But that’s what the reader under- ative, imperative, and subjunctive. Use “Freeze” becomes “froze” becomes “fro-
stands. Becomes: “Do you mind our the indicative for statements of facts zen.” “Get” becomes “got” becomes
getting all these cases?” Incorrect: “The or questions. Use the imperative for “gotten” or “got.” “Give” becomes
police objected to them possessing con- orders or commands. Use the subjunc- “gave” becomes “given.” “Go” becomes
traband.” In this example, the writer tive to express a wish, an idea contrary “went” becomes “gone.” “Grow”
did not mean, “The police objected to to fact, a requirement, or a sugges- becomes “grew” becomes “grown.”
them.” Becomes: “The police objected to tion or recommendation. Examples of “Hide” becomes “hid” becomes “hid-
their possessing contraband.” Incorrect: indicative mood: “Julia researches in den.” “Know” becomes “knew” becomes
“My parole officer objected to me liv- the library.” “Sarah writes all day.” “known.” “Lie” (horizontal position)
ing alone.” The writer did not mean Examples of imperative mood: “Be quiet.” becomes “lay” becomes “lain.” “Ride”
to write, “My parole officer objected to “Argue the motion.” Examples of sub- becomes “rode” becomes “ridden.”
me living.” Becomes: “My parole officer junctive mood: “She wishes her part- “Ring” becomes “rang” becomes “rung.”
objected to my living alone.” Incorrect: ner were here.” “If John were more “Rise” becomes “rose” becomes “risen.”
“The judge feared the Constitution aggressive, he’d be a better attorney.” “Run” becomes “ran” becomes “run.”
becoming a shield for lawlessness.” “Ashley would have passed the bar “See” becomes “saw” becomes “seen.”

NYSBA Journal | November/December 2007 | 75

“Shake” becomes “shook” becomes the past: “I was,” “you were,” “he (or phrase contained in a subject affects
“shaken.” “Shrink” becomes “shrank” she or it) was,” “we were,” and “they the number of the verb that follows.
becomes “shrunk.” “Sing” becomes were.” The past participle: “I have When you use “neither . . . nor,”
“sang” becomes “sung.” “Sink” becomes been,” “you have been,” “he (or she “either . . . or,” or “not only . . . but
“sank” becomes “sunk.” “Speak” becomes or it) has been,” “we have been,” and also,” make sure that the verb agrees
“spoke” becomes “spoken.” “Spring” “they have been.” with its nearest subject. When all the
becomes “sprang” becomes “sprung.” 6. Gerunds. A gerund is the sub- elements are singular, the verb should
“Steal” becomes “stole” becomes “sto- ject or object of a verb, infinitive, or also be singular. When all the elements
len.” “Strive” becomes “strove” becomes preposition that ends in “ing.” Use are plural, the verb should be plu-
“striven.” “Swear” becomes “swore” gerunds to avoid nominalizations, or ral. When the elements are different
becomes “sworn.” “Swim” becomes converting verbs to nouns. Incorrect: in number, the verb takes the num-
“swam” becomes “swum.” “Take” “The impeachment of his testimony ber of the closer. Incorrect: “Neither
becomes “took” becomes “taken.” “Tear” will be difficult.” Becomes: “Impeaching the judge nor his court attorney are
becomes “tore” becomes “torn.” “Throw” his testimony will be difficult.” in chambers.” Becomes: “Neither the
becomes “threw” becomes “thrown.” A gerund error occurs when the judge nor his court attorney is in cham-
“Wake” becomes “woke” or “waked” gerund modifies the wrong word in bers.” Incorrect: “Neither the judge nor
becomes “woken” or “waked.” “Wear” the sentence. Solve a gerund error in his court attorneys was in chambers.”
becomes “wore” becomes “worn.” one of three ways: (1) degerundize Becomes: “Neither the judge nor his
“Write” becomes “wrote” becomes “writ- and place the verb after the subject; court attorneys were in chambers.”
ten.” (2) bifurcate the sentence; or (3) sub- Incorrect: “Neither the judges nor
ordinate. Incorrect: “The court granted their court attorney were in cham-
the motion to suppress finding that the bers.” Becomes: “Neither the judges nor
Parallel structure police lied.” This sentence suggests
that the motion to suppress found
their court attorney was in chambers.”
Incorrect: “Neither you nor I are in
is both intelligent that the police lied. Here’s a way to chambers.” Becomes: “Neither you nor
correct the sentence by degerundizing I am in chambers.”
and a necessity. the verb after the subject: “The court Multiple subjects modified by
found that the police lied and therefore “each,” “every,” and “many” take a
granted the motion to suppress.” You singular verb. Correct: “Every court
Some irregular verbs stay the same may also split the sentence into two: attorney and every law clerk has been
in the past tense and past partici- “The court found that the police lied. told to attend.”
ple. Examples: “Bend” becomes “bent” It therefore granted the motion to sup- 8. Parallelism. Sentences are paral-
(past) becomes “bent” (past participle). press.” Another way to correct the sen- lel when nouns match nouns, verbs
“Bring” becomes “brought” in both tence is to subordinate: “After finding match verbs, gerunds match gerunds,
forms. “Catch” becomes “caught.” that the police lied, the court granted and so on. Incorrect: “A rule that is both
“Creep” becomes “crept.” “Dig” the motion to suppress.” intelligent and a necessity.” Becomes:
becomes “dug.” “Dive” becomes “dived” 7. Agreement. A verb must agree “A rule both intelligent and necessary.”
or “dove” becomes “dived.” “Fight” in numbers with its subjects. Incorrect: Incorrect: “The rule is found in the
becomes “fought.” “Hold” becomes “The color of the clouds are gray.” cases, statutes, and in the contracts.”
“held.” “Kneel” becomes “knelt.” Becomes: “The color of the clouds is Becomes: “The rule is found in the cases,
“Lay” becomes “laid.” “Lead” becomes gray.” (Color is gray.) Incorrect: “The dif- statutes, and contracts.” Incorrect: “No
“led.” “Lie” (falsehood) becomes “lied.” ference between Cardozo and Holmes, drinking, smoking or food.” Becomes:
“Lose” becomes “lost.” “Prove” becomes and between Frankfurter and Jackson, “No drinking, smoking, or eating.”
“proved” becomes “proved” or “prov- are striking.” Becomes: “The differ- Parallelism requires that paral-
en.” “Say” becomes “said.” “Show” ence between Cardozo and Holmes, lel coordinates form matching pairs:
becomes “showed” becomes “showed” and between Frankfurter and Jackson, “although/nevertheless,” “although/
or “shown.” “Teach” becomes “taught.” is striking.” (Difference is striking.) yet,” “as/as,” “both/and,” “either/
Some irregular verbs stay the same Incorrect: “Justice Jackson, as well as or,” “if/then,” “just as/so,” “neither/
in the present, past, and past participle: the hundreds of judges who emulate nor,” “not/but,” “not only/but also,”
“burst” and “hurt.” his writing style, rely on plain Anglo- and “whether/or.” Incorrect: “Not only
The trickiest verb in English is “to Saxon English.” Becomes: “Justice do I like landlord-tenant practice but
be.” Here are the variations in the Jackson, as well as the hundreds of also family law.” Becomes: “Not only
present: “I am,” “you are,” “he (or judges who emulate his writing style, do I like landlord-tenant practice, but
she or it) is,” “we are,” “you are,” and relies on plain Anglo-Saxon English.” I also like family law.” Or: “I like not
“they are.” Here are the variations in (Justice Jackson relies.) Nothing in a only landlord-tenant practice but also

76 | November/December 2007 | NYSBA Journal

AMILYLAW
CONTINUED FROM PAGE 53

family law.” Or, in the positive: “I like or independent, clause, the clause consistent. Consistently false.” Use
landlord-tenant practice and family becomes a subordinate, or dependent, sentence fragments for commands.
law.” clause. Example of a main clause: Examples: “Stop!” “Evacuate the build-
Exceptions: Use “neither . . . or,” “The attorney questions the witness.” ing!” “Get out!” Use sentence frag-
“not . . . or,” or “not . . . nor” only if Subordinate clause: “When the attor- ments as a transition. Example: “First,
the first negative doesn’t carry over ney questions the witness.” Attach the facts. Second, the law.” Use sen-
to the second negative or for dramatic subordinate clauses to main, or inde- tence fragments to negate: “The wit-
emphasis. pendent, clauses. Example: “When the ness’s testimony was honest. Not.”
9. Sentence Fragments. A sentence attorney questions a witness [subor- Also use sentence fragments to answer
fragment isn’t a short sentence. It’s a dinate clause], the judge will interrupt questions: “Have you told us the truth?
sentence that can’t stand on its own, the testimony [main clause].” Here’s Probably not.”
an incomplete sentence. A sentence a list of other subordinating conjunc- 10. “And” versus “To.” Don’t use
fragment lacks a subject or a verb. tions: “after,” “as,” “as if,” “as long as,” “and” to show causality or in an infini-
Example: “The attorney questioning “as soon as,” “as though,” “because,” tive phrase. Use “to.” Incorrect: “I went
the witness.” “Questioning” is a parti- “before,” “even if,” “even though,” to the courthouse and got the judg-
ciple modifying “attorney.” To create a “if,” “if only,” “in order that,” “in that,” ment.” Becomes: I went to the court-
complete sentence, change “question- “no matter how,” “now that,” “once,” house to get the judgment.” Incorrect:
ing” from a participle to a main verb “provided,” “rather than,” “since,” “Look and see whether the judge is
or add a main verb. Becomes: “The “so that,” “than,” “that,” “though,” on the bench.” Becomes: “Look to see
attorney questioned the witness.” Or: “till,” “unless,” “whenever,” “where,” whether the judge is on the bench.”
“The attorney was questioning the wit- “whereas,” “wherever,” and “while.” In the next issue, the Legal Writer
ness.” Exceptions: Use sentence fragments will continue with a second set of 10
Sometimes a fragment is a subor- for stylistic effect. Examples: “The rape grammar issues. Following that col-
dinate clause posing as a complete victim had the courage to testify. More umn will be columns on punctuation
sentence. If you add “although,” courage than most people would have and usage controversies. ■
“when,” or “until” in front of a main, had.” “The witness’s testimony was

NYSBA Journal | November/December 2007 | 77