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mr. garre. mr. garre: thank you, mr. chief justice, and may it please the court: two factors distinguish this case from those in which the court has found cause lacking to excuse a default: first, the state itself had a direct hand in the extraordinary events leading up to the default in this case; and second, the actions of maples attorneys, which rise to the level of abandonment, are not attributable to maples under agency law or other principles that this court has invoked in determining when attorney conduct may be imputed to a client. that this court has invoked in determining when conduct can be with a client. it the default at issue in this case is not fairly attributable to cory maples. the decision of the 11th circuit should be reversed. for either or both of those reasons, the default at issue in this case is not fairly attributable to cory maples and the contrary decision of the eleventh circuit should be reversed. chief justice john g. roberts: you talk abo ....

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