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Legal scholars have filled books, treatises, magazines, journals and law reviews with various writings ranging from highly intricate and complex theses to oversimplified and homogenous explanations. In all its forms, legal scholarship has been both touted and taunted by external and internal critics throughout the years. Some suggest that legal scholarship should holistically "frame recommendations to responsible decision makers," and more specifically "help the reader understand law." Others suggest that it should be used to bring "restraint, proportion, perspective and atmosphere" into the legal landscape and society at large. Whatever its stated purpose and whether it be doctrinal, descriptive or practical, legal scholarship remains an intricate and influential factor in legal academia, the legal system as a whole, and shaping cultural and professional discourses. As such, the varied and broad topics of legal scholarship (the empirical, the interpretive, the normative, and the prescriptive) provide innumerable opportunities for legal scholars: opportunities that are truly a "gift" as noted by Professor Lefkowitz. This "gift" should not be taken for granted, and "should comport with [both] the goals and attributes of the academy"' and with the goals and conditions of the legal profession.