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"It was simply using the word agreement".
"I was simply using the brothel as a working laboratory" – probably my favourite excuse ever.
They are simply using the riots to confirm previously held beliefs about young people.
"I would argue that simply using the term 'haystack' is misleading.
Simply using the companies' values would make it impossible to compare various executives' options grants.
The function is called by simply using the function name and listing the parameters in parenthesis.
Simply using the past relationship between SST and drought was not a sufficient explanation.
But Garage Obama is also freed up, beyond simply using the N-word.
Strategies range from scouring the Internet for used books to simply using the library copy.
Other Republicans are simply using the rule to rekindle fury over health reform.
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She said Trump was simply using the country as an example to say he wanted "an individual merit-based system".
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com