6. Plausibility

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6. Plausibility

It has been demonstrated that the particular biographical narrative through which we choose to view the subject of our study will powerfully influence our reading and interpretation of the evidence. Extending this idea further with respect to the

Shakespeare authorship question, I have shown that the historical evidence yields significantly different interpretations when viewed through different authorship paradigms. How, then, are we to choose between two or more paradigms that are mutually exclusive? The obvious answer – that there is usually far more evidence for one than the other – is complicated when we take into account the existence of confirmation bias, the unconscious filtering out of evidence which conflicts with our pre-existing beliefs. The second most obvious answer, plausibility, is also more complex than it might at first appear.

It is important to understand that the evidence for all authorship candidates – including Shakspere of Stratford – is circumstantial.The fact remains that there is no primary source evidence linking William Shakspere of Stratford to the poems and plays attributed to him. There is strong primary evidence that he was a business man and theatre share-holder, scant and dubious primary evidence for his acting, but no documents at all from his lifetime that support his being a writer. The argument that

‘his’ name on the pre-1616 quartos constitutes primary evidence is circular, relying as it

Barber, R, (2010), Writing Marlowe As Writing Shakespeare: Exploring Biographical Fictions DPhil Thesis, University of Sussex. Downloaded from www. rosbarber.com/research. 128 does upon the assumption that the name William Shakespeare (or Shake-speare) refers to Shakspere of Stratford, and is not a pseudonym. Similarly, pre-1616 references in other texts to the writer William Shakespeare (or Shake-speare) cannot be assumed to refer to Shakspere; every single one is demonstrably an impersonal reference, requiring an awareness only of the author’s works and writing style, not personal knowledge of the man. As Price concludes,

‘the authorship attribution in the Folio constitutes the first historical evidence identifying Shakspere in personal terms as the dramatist. The evidence is posthumous, and for no other writer of Shakespeare’s time period are we asked to trust such ambiguous and belated information, uncorroborated by any solid documentation left during the author’s life, as evidence of authorship.’ (Price, 2001: 194)

I have confined this thesis largely to addressing the mythography created by

Marlowe and Shakespeare biographers, and exploring what happens when primary texts are read through the Marlovian authorship paradigm. The main weaknesses of the orthodox paradigm are not part of my brief, and have in any case been thoroughly explored in Price’s Unorthodox Biography (2001). However, there is a substantial body of evidence that argues against Shakspere’s being the author of the works attributed to him that continues to go unacknowledged by orthodox academics.104 Each piece of evidence on its own is not particularly significant, but taken together, the evidence creates reasonable doubt of Shakspere’s authorship – at least for those whose reticular activating system allows them to consider an alternative paradigm. That most of the evidence consists in anomalies and missing data should not be discounted. David

Schum, an academic and lawyer who has worked for the CIA and specialises in the analysis of evidence, began a presentation to the British Academy conference ‘Enquiry,

Evidence, and Facts’ with an extract from Conan Doyle’s Silver Blaze to demonstrate

104 Owing to the impossibility of cross-paradigm communication, I am aware that orthodox scholars will disagree with this statement.

Barber, R, (2010), Writing Marlowe As Writing Shakespeare: Exploring Biographical Fictions DPhil Thesis, University of Sussex. Downloaded from www. rosbarber.com/research. 129 that the absence of something we would expect to be there qualifies in itself as an important piece of evidence that any explanatory narrative must account for (Schum,

2007).

‘ “Is there any point to which you would wish to draw my attention?” “To the curious incident of the dog in the night-time.” “The dog did nothing in the night time!” “That was the curious incident,” remarked Sherlock Holmes.’ (Doyle, 2001: 413)

Is it plausible that a man as passionately involved in the English Language as this author, whose works garnered the praise of literary men throughout twenty years of output, would leave behind absolutely no letters to anyone?105 That an author who filled his plays with educated woman, would leave his daughters functionally illiterate?

That his genius would pass unnoticed at a grammar school which awarded university scholarships to talented pupils? Is it plausible that a writer whose vocabulary exceeded

29,000 words, and whose source books, as identified by scholars, number nearly 300, would leave no evidence of a single book owned, borrowed, or written in? That unlike every literate person of the period he would not have developed a consistent signature?

That despite being one of the most famous authors of his generation whilst alive as well as afterwards, he would leave no trace of a life amongst other writers in London or elsewhere, not a scrap of unambiguous personal testimony? Is it plausible that a man who had no university education would use, in a metaphor, terms that are specific to

Cambridge undergraduates, or show detailed knowledge of people who worked there or plays performed there (Cockburn, 1998: 223-34)?106 That he would exhibit first-hand knowledge of Italian towns and cities that most scholars agree he never visited (Prior,

105 Given that letters to or from his contemporaries Ben Jonson, Thomas Nashe, Gabriel Harvey, Edmund Spenser, Samuel Daniel, George Peele, Michael Drayton, George Chapman, William Drummon, John Marston, John Lyly, Thomas Lodge, Thomas Dekker, Thomas Kyd and Philip Massinger are extant. 106 See ‘Shake-Speare a Cambridge University Man’ in COCKBURN, N. B. (1998) The Bacon Shakespeare Question : The Baconian Theory Made Sane, Limpsfield Chart, N.B. Cockburn. Also BOAS, F. S. & SHAKESPEARE, W. A. M. (1923) Shakespeare & the Universities, and Other Studies in Elizabethan Drama, pp. vii. 272. Basil Blackwell: Oxford.

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2008, Cockburn, 1998: 705-12)?107 That despite being extremely litigious in all documented areas of his life he would attempt no legal redress when his work was plagiarised and pirated? Is it plausible that a follower of Ovid, who celebrated and pursued immortality through verse, and whose sonnets express a repeated yearning for literary immortality, could be the same man that scholars agree showed absolutely no interest in the publication of his work?108 That after more than two hundred years of extensive research, with more than seventy documents relating to his life retrieved, the biography of Shakespeare alone (amongst two dozen writers of the period) would be bereft of those items we would expect to find if the biographical subject were a writer?

These are only a fraction of the inconsistencies that have led to the birth and continued rise of Shakespeare scepticism. Each one on its own may be (and in many cases has been) explained away by orthodox scholars; but taken together, non-

Stratfordians believe they constitute a substantive case against the incumbent candidate’s authorship. Stephen Greenblatt, aware of the sharp contrast between the biographical and literary Shakespeare, refers to him as ‘a master of double consciousness’. Since human beings (with the possible exception of those suffering from multiple personality disorder) generally possess only a single consciousness, a far simpler explanation for this phenomenon is that we are actually looking at two different men, but this is the rationale that falls beyond the academic pale. For Shakespeare

107 Italian places of which Shakespeare demonstrates first-hand knowledge include Mantua, Padua, Milan, Verona, Venice, Bergamo and Bassano. Roger Prior’s fascinating evidence for Shakespeare’s first-hand knowledge of Bassano is defeated by his effort to shoe-horn this evidence into the orthodox narrative. A necessarily short sojourn abroad for the traditional author/actor/share-holder, and the freshness of the Italian references, leads to his suggestion that The Taming of the Shrew, Romeo & Juliet, A Midsummer Night’s Dream, The Merchant of Venice, Love’s Labour’s Lost and Othello were all written in the first half of 1594. 108 Erne’s 2003 book made a powerful case for the author’s yearning for literary immortality, but the evidence of this (from Shakespeare’s own texts) is so at odds with the documentary evidence relating to the orthodox incumbent, Shakspere, that the idea is still widely rejected. ERNE, L. (2003) Shakespeare as Literary Dramatist, Cambridge, UK ; New York, Cambridge University Press.

At first sight the Marlovian case, with its necessity for a faked death, looks no more plausible than the orthodox one. Certainly there is nothing but circumstantial evidence to support it. However, although the idea of a faked death seems initially to be absurd, it is not impossible, and there are a number of conditions that favour it. One is the lack of agreement between scholars as to whether Marlowe’s inquest document covers a planned assassination, or is a truthful account of an accidental stabbing.

It is a fact that Lord Burghley, at loggerheads with Whitgift and losing ground to him in terms of Privy Council influence (Sheils, 2004), failed to prevent the execution of puritan John Penry at the Archbishop’s behest, the day before Marlowe met with

Poley, Frizer and Skeres at Deptford (Cross, 2004). As Kuriyama points out, the men present with Marlowe at widow Bull’s house, though known to be expert liars, were not assassins (Kuriyama, 2002: 139). The supposed murderer, Ingram Frizer, was a loyal servant of Marlowe’s friend and patron Thomas Walsingham. Swiftly pardoned for the killing, Frizer was doing business for Walsingham the very next day, and continued in the service of the Walsinghams to the end of his life, being rewarded by James I with a series of leases in reversion of crown lands (Bakeless, 1942: I, 170).

It has been repeatedly demonstrated that those put forward as the instigators of

Marlowe’s murder have no reason to murder him (Hammer, 1996). In any case, were an assassination required, why not simply stab him in a dark alley? Thus Downie and

Kuriyama conclude Marlowe was stabbed as a result of a fight, as the inquest document states. The option that the inquest document covers up not a murder but a faked death is dismissed as ridiculous. Yet it is worth imagining oneself in Marlowe’s position.

Consider that you have been arrested under suspicion of heresy and atheism, a charge

Barber, R, (2010), Writing Marlowe As Writing Shakespeare: Exploring Biographical Fictions DPhil Thesis, University of Sussex. Downloaded from www. rosbarber.com/research. 132 for which you can be executed without evidence, as a government lawyer had recently confirmed. Thanks to your colleagues in the intelligence services, you have both the means and opportunity to escape prosecution; you certainly have the motive. The only conditions under which you can hope to escape without being pursued is if your prosecutors believe you are dead. Under these conditions, it is difficult to imagine a person who would not make a bid for their own survival.

Even these times of photographic passports and DNA analysis, people fake their own deaths in circumstances considerably less life-threatening than those Marlowe found himself in.109 Naturally we only hear about a faked death where it has been exposed to be fraudulent, but that does not mean that a proportion of faked deaths are not successful, and indeed it would be somewhat extraordinary if the faked deaths that are discovered represent one hundred per cent of those carried out. The faked death theory offers the potential to answer the objections both of those who argue against assassination and those who argue against accident – explaining those elements of the documentation that hint at cover-up, while allowing that the people implicated in his death were friends and colleagues, rather than enemies, of Marlowe.

Though the purpose of the meeting cannot be known, it is relevant and should be considered. Marlowe at the time of the Deptford incident was on bail and reporting daily to their Lordships, obliged to stay ‘within the verge’, that is, twelve miles of the

Queen’s person. Although some scholars insist he was not in danger, it is clear from

Richard Cosin’s 1593 defence of ex officio oaths that Marlowe would be likely to face the death penalty for the accusations of atheism contained in the Baines Note. The all- day meeting (they talked in ‘quiet sort’) needs to be understood in this context. There

109 A list of some of the most interesting faked deaths of recent times, including famous people (MP John Stonehouse, author Ken Kesey) and a man who ‘posthumously’ wrote a book under an assumed name, can be found at http://www.marloweshakespeare.org/FakedDeaths.html

As previously noted, the most striking quality that all three men present with

Marlowe have in common is that they are accomplished liars. All three are also connected to Marlowe’s patron Thomas Walsingham – a man whom Edward Blount,

Marlowe’s publisher, and publisher of Shakespeare’s First Folio, acknowledges as

Marlowe’s friend five years later, in 1598. Peter Farey has discovered that the foreman of the jury – who did not hail from the geographical area from which the jury would usually be drawn – is also connected to Thomas Walsingham (Farey, 2009).

Poley’s cover as a spy had been blown during the Babington plot, but he continued to work for the government as ‘an operational chief or section head, running a small intelligence network in the Low Countries, and reporting to Vice-Chamberlain

Heneage and the Cecils’ (Nicholl, 2002: 299). A payment to Poley covering 8 May to 8

June 1593 states explicitly that he was in the Queen’s service ‘all the aforesaid tyme’:

‘To Robert Poolye upon a warrant signed by Mr vicechamberlayne dated at the Courte xiimo die Junii 1593 for carryinge of lettres in poste for her Majesties speciall and secrete afaires of great ymportaunce from the Courte at Croyden the viiith of Maye 1593 into the Lowe Countryes to the towne of the Hage in Hollande, and for retourninge backe againe with lettres of aunswere to the Courte at Nonesuche the viiith of June 1593, being in her Majesties service all the aforesaid tyme - xxxs.’ (Boas, 1940: 267)

As Peter Farey points out, this last statement is ‘unique amongst the warrants listed, and clearly tells us that Poley was on duty that day at Deptford.’ It is worth asking, if he had returned from the Hague to Deptford at that point, why it took another eight days for him to deliver the letters to the Court at Nonsuch. One point worth considering for relevance is Kyd’s testimony that Marlowe ‘would persuade with men of quality to go unto the K[ing] of Scots, wh[i]ther I hear Roydon is gone, and where if he had lived, he told me when I saw him last, he meant to be.’ As Nicholl points out, Roydon

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(connected to one of the Deptford trio, Nicholas Skeres, as far back as 1582) can only have gone to Scotland within the last month, since Skeres testified on 23 April 1593 that he was at that time living at a shoemaker’s house in Blackfriars (Nicholl, 2002: 30,312).

Thus though Kyd claims that he ‘did refrain from his company’, we can discern that it was within the month that Marlowe told Kyd he intended to follow Roydon to Scotland.

Poley’s chief recommendation to the Babington circle had been that he ‘knew the best ways to pass into Scotland’ (Seaton, 1929: 284). Thus it has been postulated that

Poley’s otherwise unaccountable eight-day delay (given these were ‘secret affairs of great importance’) could be accounted for in his accompanying Marlowe to a place of safety.

In his article ‘Marlowe’s Sudden and Fearful End’, Farey considers at length the various possible reasons for the meeting a Deptford. The idea of a ‘feast’ hosted by

Frizer, as suggested by Vaughan, does not tally with the dire situation we know

Marlowe to be in. Nor is it likely that Poley, on duty and carrying letters ‘in poste’ (i.e. in a hurry) would stop off for a relaxing day with friends (and there is no evidence he knew Frizer). Paul Hammer’s suggestion that the meeting was for Frizer and Skeres to recoup a debt from Marlowe, a meeting which subsequently went wrong, does not explain the presence of Poley, nor why such a meeting would take all day. If the purpose of the meeting were to murder Marlowe, then it remains to be answered why such an elaborate means of dispatching him were necessary, and what motivation

Thomas Walsingham and the Cecils could possibly have for wanting Marlowe dead.

Due process was likely to lead to his death in any case, making a complicated scenario for his murder unnecessary.

If this were assassination, there is no explanation why a meeting planned to end with his murder would take eight hours. If the meeting were to plan Marlowe’s escape

Poley alone had sufficient knowledge for such a purpose. To fake a death, however, requires three people: one ‘killer’ and two witnesses. Since they would have to appear before a jury, they would need to be consummate liars, as these men were. A faked death would save Marlowe from torture and execution, ‘the most likely objective of those men for whom the three people there with Marlowe would have had most loyalty.’

Thus, Farey argues, a faked death is the only logical reason why these particular people would meet at this particular time.

The location is also important. Of the four men who met, three are known or suspected to have worked for Sir Francis Walsingham’s (and later the Cecils’) network of intelligence agents, and two were involved in dubious money-lending schemes that involved deception. The underworld dealings of Frizer and Skeres in particular have been stressed. The venue for the meeting, however, was in the house of a highly respectable woman with court connections. Eleanor Bull was a ‘cousin’ of Chief

Gentlewoman of the Privy Chamber Blanche Parry, a trusted royal servant who had been close to the Queen since Elizabeth’s infancy and who was in turn a ‘cousin’ and good friend of Lord Burghley.

Deptford, a stopping off point for travel to and from the continent, can only be considered ‘within the verge’ allowing some leeway for the accuracy of Elizabethan miles. Nevertheless the inquest was conducted as if within the verge by the Queen’s

Coroner, William Danby. It would be normal procedure to involve the Kent County

Coroner, but Danby presided over the case alone. Danby had been a contemporary of

William Cecil at the Inns of Court some fifty years earlier, and had been his close colleague at court for the past four.

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It has been claimed in the past that the Queen’s special interest in the case is indicated by the wording of the writ of certiorari sent to William Danby on 15 June, or by the wording of Frizer’s pardon, which states

‘We therefore moved by piety have pardoned the same Ingram ffrisar the breach of our peace which pertains to us against the said Ingram for the death above mentioned & grant to him our firm peace. Provided nevertheless that the right remain in our Court if anyone should wish to complain of him concerning the death above mentioned In testimony &c Witness the Queen at Kewe on the 28th day of June.’

However, the wording of both documents is standard. Nevertheless, the

Queen’s interest in the case is evident in so far as a copy of the Baines Note was made, altered, and ‘sent to her H’, a fact confirmed by Drury, who describes how he was responsible for setting down the ‘vyldist artyckeles of Athemisme that I suppose the lyke was never known or red of in eny age’ which ‘were delyvered to her hynes and command geven by her selfe to prosecut it to the fule.’ From this we might ascertain that the Queen followed Baines’s urging to put an end to Marlowe’s spouting of

‘damnable opinions’. Riggs followed this logic to theorise that the Queen sanctioned

Marlowe’s murder, but there is more than one way of stopping a mouth. One of the many interesting changes made to the Note delivered to her Highness was the alteration of the title, from

‘A note conteyning the opinion of one Christofer Marlye concernynge his damnable opinion and Judgment of Relygion and scorne of Gods worde, who since Whitsundy dyed a suden and violent deathe’ to

‘A note delived on whitsun eve last of the most horrible blasphemes and damnable opinions uttered by XpoferMarly who within iij dayes after came to a suden & fearfull ende of his life.’

The necessity for changing ‘a sudden and violent deathe’ to the more equivocal phrase

‘a sudden & fearfull ende of his life’ is not clear, except in the case of a faked death, where the latter might be deemed to have avoided the open lie.

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None of this evidence proves that Marlowe’s death was faked, but all of the evidence is consistent with that theory, whereas the ‘accident’ and ‘assassination’ theories fail to address or adequately explain certain items of the evidence. This does not mean that Marlowe’s death was faked, only that this hypothesis appears to offer the best explanation for the evidence that has survived. That is, in respect to the necessary process of ‘joining the dots’ (Schum, 2007), the faked death theory joins all of the dots of evidence and leaves none unaccounted for.

As previously discussed, a faked death is not, in and of itself, implausible. On closer analysis what is implausible is not the original deception, but the idea that it was so successful that some of the greatest literary and critical minds might have been under a false impression for four centuries. And yet I contend this is by no means beyond the realms of possibility.

Those who entertain the Shakespeare authorship question are frequently dismissed as ‘conspiracy theorists’, a derogatory term which allows the orthodoxy to avoid any serious consideration of doubt. Yet though ‘conspiracy theory’ is a relatively recent term, the word ‘conspiracy’ has roots beyond Chaucer for the simple reasons that there have been conspiracies throughout history – indeed, Shakespeare himself dramatized some of the more famous ones. The age in which Shakespeare lived and wrote might be reasonably characterised as the age of conspiracy: the Babington Plot,

Main Plot, Bye Plot, Stanley Plot and Gunpowder Plot being just a handful of those plots unearthed by the Privy Council. Thomas Walsingham, Robert Poley and Nicholas

Skeres were involved in the Babington Plot. The government of the day ensured that these Catholic plots became public knowledge; but how likely is it that Lord Burghley and Sir Robert Cecil did not indulge in conspiracies of their own? Indeed, David Riggs believes that what Marlowe and Baines were up to at Flushing was part of a government

Barber, R, (2010), Writing Marlowe As Writing Shakespeare: Exploring Biographical Fictions DPhil Thesis, University of Sussex. Downloaded from www. rosbarber.com/research. 138 scheme to infiltrate Sir William Stanley’s regiment, after Stanley had made clear his intent to assassinate the Queen. We do not have any details; to have the highest chance of success, a secret operation is best not documented.

By necessity, a successfully faked death will look like death itself, and will not have been generally doubted. A cursory examination of human society will reveal that on the whole, people believe what they are told, particularly by authority figures. They also believe what they want to believe. The accounts of Beard and Meres, though wildly inaccurate, were readily believed, so much so that their view of Marlowe as a blasphemous atheist who got what he deserved still dominates the cultural consciousness. One can conclude it suited Elizabethans to envisage such a death for

Marlowe, and there would be no reason to question so ‘fitting’ an end, especially as it was clearly utilised by the Church (both Beard and Meres were clergymen).

Reasonably in the circumstances, any doubts about the veracity of Marlowe’s death among Marlowe’s friends and fellow writers appear to have been expressed in the most guarded of terms.

This raises another issue of plausibility. Reading the enigmatic references of

Marlowe’s fellow writers as evidence that those authors understood the name ‘William

Shakespeare’ to be a front for a suppressed colleague invites the question, how much of an open secret might it have been, and still remain secret? Those who ‘knew’, under this reading of the evidence, include Ben Jonson, John Marston, John Davies of

Hereford, William Covell and Gabriel Harvey. Poley, Frizer and Skeres must be numbered amongst the ‘knowing’ – plus Thomas Walsingham. If we read the revision of the Baines Note as part of the scheme, then certain members of the Privy Council

Barber, R, (2010), Writing Marlowe As Writing Shakespeare: Exploring Biographical Fictions DPhil Thesis, University of Sussex. Downloaded from www. rosbarber.com/research. 139 would also be party to it.110 Under these circumstances, with so many people apparently in possession of confidential information, is it plausible that such a secret could be sustained?

There is at least one historical precedent that would allow us to answer this question in the affirmative. In the Second World War, hundreds of people were privy to the secret workings of Ultra (thus named because it was ‘Ultra-secret’), but the project was not known about until the government allowed it to be revealed to the public nearly thirty years later (Winterbotham, 1974). In Marlowe’s case, to reveal that his death had been faked would be to risk being the cause of not only his death but very likely the imprisonment, death and ruin of those who had assisted him. Indeed, it might even be perceived as an action that would be dangerous to the self: Richard Baines, who might be regarded as chiefly responsible for the demise of Marlowe (at least as an identity) in

1593, appears to have been framed for a capital crime the following year by an unnamed man with whom he unwisely went drinking, and the story of his downfall and execution was famous enough to provoke a ballad (Kendall, 2003: 308-31).111 Any revelation of this kind regarding Marlowe would also likely have dire consequences for the body of work associated with the name ‘William Shakespeare’. Those who wished these plays and poems to be given the respect they deserved, and did not want to be responsible for the death of a talented man whose prosecution seems to have been the result of a personal vendetta provoked in the line of loyal service to his country, would have had no motivation for divulging his secret in an open way.

110 Peter Farey has recently argued that Marlowe’s silencing and exile was a compromise agreed between the two key factions of the Privy Council: the Cecil faction, who wanted to keep him alive and potentially of use to them, and the Whitgift/Puckering faction, who wanted him prosecuted and executed for his religious opinions. The faked death would allow his survival whilst simultaneously making him an example of what God does to atheists and blasphemers. Interestingly, the hand that altered the Baines note has been identified as Puckering’s. 111 The case for Baines being this man, rather than the Waltham rector proposed by Nicholl and Kuriyama, is persuasive (308-31). The cup-stealing scene in Doctor Faustus between ‘Dick’ and ‘Robin’ bears such intriguing parallels to the Baines case that it looks strongly like a post-1594 addition.

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A further possibility has recently been postulated by Peter Farey: with such a public, well-documented and government-sanctioned ‘death’, anyone expressing a belief that Marlowe might have survived could have been threatened with incarceration in Bedlam. That some nevertheless felt the urge to hint at what they knew, or thought they knew, is indicated by the striking number of enigmatic references to Shakespeare, and absence of direct ones.

Plausibility, then, is in the eye of the beholder. What a person will consider plausible will depend upon the paradigm through which they interpret the data. The

‘alternative’ paradigm is bound to look implausible because it doesn’t accord with one’s perceptions (those perceptions, in turn, being shaped by one’s beliefs). Since confirmation bias will not allow us to fairly weigh the evidence, or even decide what is relevant enough to count as evidence,112 and plausibility is demonstrably subjective, how then are we to ascertain which theory is the most likely explanation for the data that exists? David Schum, whose background in probability gives him unique insight into the theory and methods of evidence, advocates the ‘imaginative act’ of ‘telling a story, or constructing a scenario’ as ‘a most valuable heuristic device’ (Schum, 1999:

446). According to Schum, the most likely explanation for the information we have received will be the narrative that joins the greatest number of dots into a coherent scenario, with the least amount of fudging, dots left out, and inexplicable data.

112 Schum, speaking of the unfortunate tendency to discard information too early in an investigation, illustrates another example of confirmation bias when he states that ‘Some of the information or data being gathered will be perceived as relevant to the case at hand and will then be called evidence. In many situations, the relevance of an item of information is not initially appreciated when it is first received.’ SCHUM, D. A. (1999) Marshaling Thoughts and Evidence During Fact Investigation. South Texas Law Review, 40, 401-54.

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