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In contrast with the federal Constitution, seven state constitutions have provisions that explicitly provide a right to a clean and healthy environment, although the language in these Environmental Rights Amendments (ERAs) varies from state to state.4 New Yorks, for example, states that [e]ach person shall have a right to clean air and water, and to a healthful environment.5 Pennsylvanias ERA,6 among the earliest to be adopted and the most-cited, has been a source of litigation related to the state legislatures enactment of oil and gas laws that were found to have violated the states trust responsibility.7 Montanas ERA was central to Held v

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Johnston, claiming he was defamed and demanding an apology.10 They also wrote to television station KABC in Hollywood, alleging that the advertisement was false and defamatory and demanding that the broadcasts end immediately.11 They told Asher/Gould, Your creation of an intentionally altered videotape is clearly outside the limits of legal or ethical behavior, and my client shall hold your agency, and everyone in this project, personally responsible.12 The lawyers demanded that Asher/Gould set aside and preserve every documentin your possession or custody and control relating to the development, production, and distribution of the offending commercial.12 Finally, they demanded that DHS director S

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