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If you are a student working on a legal memorandum, you may think the answer to the question posed by the title of this Article is that they can both make you cry. This Article may help you avoid tears by giving you a way to review your work. The legal memorandum is like an onion because it is a whole made up of many layers. These layers cover each other in levels that can be cross-sectioned and examined in place without losing the sense of the whole. The guidelines offered for that examination follow the priorities of your legal reader. These guidelines should help you with the complex task of editing your memorandum, while guarding against straying from the core purpose of your memorandum- the presentation of your legal analysis.