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marketing credit repair business 1996 same; United States v. Seale, 20 F. 3d 1279, 1285 n. 7 3d Cir. 1994 dicta that Simon and Schuster does not prohibit fine that includes proceeds of expressive activity relating to crime, but rather prohibits the singling out of those proceeds for special treatment while ignoring other assets. Judicial reform is the complete or partial political reform of a country's judiciary. Judicial reform is often done as a part of wider reform of the country's political system or a legal reform. The President of the Constitutional Court of the Russian Federation, Valery Zorkin, gives in his article, "Twelve Theses on Legal Reform in Russia", first published in Russian magazine «Legislation and Economics», N. 2, 2004 an explained correlation between legal and judicial reform: "Complete legal reform should normally include not only judicial reform, but also reform of various aspects of the structural system and content of legislation, legal education, legal awareness by the population, and also the corporate consciousness of the whole legal community. Judicial reform usually aims to improve such things as law courts, procuracies, advocacy bar, inquest, executory processes, and record keeping. " .

3055 1993 under Simon and Schuster, district court cannot limit a restitution order solely to the income the defendants earn on speech associated with their criminal activities; United States v.