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"The inherent and fundamental difference between actions at law and suits in equity cannot be ignored." So said the New York Court of Appeals nearly seventy-five years after the legislature had solemnly ordained that "The distinction between actions at law and suits in equity, and the forms of all such actions and suits heretofore existing, are abolished; and, there shall be in this state, hereafter, but one form of action, for the enforcement or protection of private rights and the redress or prevention of private wrongs, which shall be denominated a civil action."

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The Union of Law and Equity, 25 Columbia Law Review 1 (1925)

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