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A private nuisance is an action or behavior that is injurious to health or is indecent or offensive to the senses, or an obstruction to the free use of property, so as to interfere with the comfortable enjoyment of life or property. CAL

This immediately led to speculation that the show's primary villain is very much alive, and will continue to antagonize Mulder throughout the 2016 miniseries

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Their results indicate that the prevalence of symptoms is strongly related to the number of cigarettes smoked per day

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