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94 N.D. L. Rev. [i] (2019)

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          NORTH DAKOTA LAW REVIEW

Volume 94                                 2019                                Number 1


        2018-2019
BOARD OF EDITORS


     MATTHEW KOPP
       Editor in Chief


    NICK  SURMA
    Managing Editor
 LISA HOCHHALTER
Outside Articles Editor


     JOCELYN SOLHEIM
       Technical Editor
CASSANDRA FREDERICKSON
       Research  Editor


    ELLIE  STEFFES
 Student Articles Editor


ASSOCIATE EDITORS


DEREK  PINNICK


STAFF


    LONI BRYANTT
ALEXANDRA  CARTHEW
   KAITLYN HENKE
   CARL KARPINSKI
   AARON PULANCO
   KRISTIAN SUAREZ


KATIE  CARPENTER
HUGH   GRINDBERG
JUSTINE HESSELBART
SHAUN  MCNAMARA
ANTHONY   SACCOCIO


LOGAN  CARPENTER
  COREY HALLER
ALEXANDER   HUNT
JACKSON   PASCO
BRENDAN   SAILER
  VICTORIA ZUKE


                                   FACULTY ADVISOR
                                   MICHAEL  S. McGINNISS

                                 NORTH DAKOTA  LAW  REVIEW
                                     is the journal of the
                           State Bar Association of North Dakota
                                 ZACHARY  PELHAM, President
                         AUBREY  J. FIEBELKORN-ZUGER, President-Elect
                             PATRICK J. WARD, Secretary-Treasurer
                             TONY  J. WEILER, Executive Director
                                1661 Capitol Way, Suite 104LL
                                Bismarck, North Dakota 58501
              The views herein expressed are those of the individual authors and are not
          necessarily those of the State Bar Association or the NORTH DAKOTA LAW REVIEW.

    The NORTH DAKOTA  LAW REVIEW (ISSN 0029-2745) is a triannual publication by the University of North
Dakota School of Law, 215 Centennial Drive, Stoo 9003, Grand Forks, North Dakota 58202-9003. Subscription
charges are $30.00 per volume or $10 per issue  us postage). Postage Paid at Grand Forks, North Dakota, and
additional mailing offices. POSTMASTER: Send ss changes to ORTH DAKOTA LAW REViEW, University of
North Dakota School of ILa, 215 Centennial Drive Stop 9003 Grand Forks, ND 58202-9003.
    Each issue is provided to subscribers in electrotic form unfess the subscriber requests to receive the hard copy by
contacting the LAW REVIEW. With the release ofa new issue, each subscriber will receive an e-mail notification that
the issue is available electronically at www.law.und.edu/LawReview/. The LAW REVIEW is not responsible for missed
issues due to failure to notify the LAw REVIEW of a change of address. Members of the North Dakota Bar must notify
the LAW REVIEW of any change in address.
    Members of the North Dakota Bar Association receive the LAw REVIEW for a fee of$1 0.00 per year, automatically
extracted from their yearly dues. Subscriptions will be renewed automatically unless notice of cancellation is received.
    Questions concerning business and requests for reprints should be addressed to NOR1M DAKOTA LAW REVIEW,
University ofNorth Dakota School ofLaw, 215 Centennial Drive, Stop 9003, Grand Forks, North Dakota 58202-9003.
Telephone: (701) 777-2941. Fax: (701) 777-2217. Visit the NORTH DAKOTA LAW REVIEW'S web page at:
http//www.law.und.edu/law-review/.
    The NORTH DAKOTA LAW REVIEW is a member of the National Conference of Law Reviews.
    Copyright C 2019, by the NORTH DAKOTA LAW REVIEW.


MARCEDES  HURD


GREG SINNING

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