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HOUSE_OVERSIGHT_017714 - HOUSE_OVERSIGHT_017766
e fundamental requisite of due process of law is the opportunity to be heard" (quoting Grannis v. Ordean, 234 U.S. 385, 394 (1914))). 211 See, e.g., Irvin v. Dowd, 366 U.S. 717 (1961) (holding that prisoner should have been granted change of venue where pre-trial publicity caused prejudice). But cf. Fle
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