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While legitimately produced and sold e-cigarette cartridges are not directly implicated in a large number of VAPI cases diagnosed to date, the proposed ban also seems motivated by a more general desire to curb the popularity of e-cigarettes with teens, which has grown rapidly, and is often linked to developing an addiction to traditional cigarettes later in life

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In explaining why permanent disbarment was warranted, the court pointed to Burns disciplinary history dating back to 2006

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