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1. Introduction PART I: THE THREE COURTS - RAW ANALYSIS 2. The French Bifurcation 3. The American Unification 4. The European Union: Discursive Bifurcation Revisited PART II: BIFURCATION 5. Similarity and Difference 6. France: How is the Discursive Bifurcation Maintained? 7. The ECJ: The French bifurcation reworked PART III: COMPARISON 8. The Sliding Scales 9. Apples and Oranges 10. On Judicial Transparency, Control, and Accountability 11. On Judicial Debate, Deliberation, and Legitimacy 12. Concluding Postscript Bibliography
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