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The defendant, by practicing, enforcing and compelling discrimination based on race and color, as aforecited in paragraphs "NINTH" to "FOURTEENTH" inclusive, is exercising and carrying out, and threatens to continue to exercise and carry out, its corporate franchese (sic), privileges, rights, objects and activities in a manner contrary to the public policy of the State of New York.
For instance, the aforecited poem sampling Walker's Appeal ends with a cliche: "Build a stone place / Where memory may safely take refuge.
Amtrak has consistently fallen short of the goals set forth by the aforecited federal laws and fallen short of maintaining a nation rail system that is effective, which by definition is safe for passage and commerce and free from defects.