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They could have simply absconded with it.
It could have simply been "an editor".
The result could have simply been an aberration.
Mr Cameron could have simply given that reassurance.
Or I could have simply left the lamb plain.
Berman could have simply said: "McGwire's back hurts.
He believes the removal of the exception could have simply been an oversight.
Not long ago, the Chinese government could have simply mandated change.
Or he could have simply asked out, and few could have blamed him.
He could have simply collected a nice sum and just gone fishing.
He could have simply moved in with his parents for a year or more.
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