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That is simply false.
Unfortunately, that was simply false.
This is quite simply false.
Both statements are simply false.
But that claim is simply false.
"These and other claims were simply false.
Any suggestion otherwise is simply false".
It was widely derided as mealymouthed, ignoble, or simply false.
As study after study has shown, that's simply false.
They turned out to be unfounded, speculative or simply false.
Mr. Sperling said Mr. Ryan's claim was "simply false".
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