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Judge Adair's ruling said the indictment of a Krolicki aide, Kathryn Besser, was also insufficient.
There is also insufficient point, purpose and narrative clarity in the long flashback that follows.
A smaller increase of $1.5 billion a year was also insufficient, the panel concluded.
The trouble is that, on almost all counts, while these are impressive they are also insufficient.
The fact that interest rates are low is also insufficient evidence of the markets' assessment of UK debt levels.
It's a thorny, boggy path, on which attributes like honesty and sincerity are indispensable (just ask James Frey) but also insufficient (just ask everyone else).
Controls are also insufficient, especially in southern Italy, even though a number of agencies are entrusted with keeping tabs on businesses.
But Mora's best was not enough in a 6-3 loss, and the Mets have decided it is also insufficient to sustain them through the pennant race.
Initiatives such as open data, e-petitions and opening-up publicly-funded research are innovative but, given the extent of public disengagement from politics, also insufficient.
There were also insufficient measures in place to separate workers from moving vehicles, and failure to control risks to workers from lifting heavy items.
Individual ministers (such as David Blunkett in these pages) have certainly devoted thought to ways of refurbishing "Britishness" and "Englishness", but although this is worthy stuff, it is also insufficient and backward-looking.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com