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See the Model Penal Code. See 2 W. LaFave, Substantive Criminal Law § 13.3(d) at 367 n. 71 (2d ed. 2003). Section 2.06 of the Model Penal Code. Comment 9(c) to section 2.06 addresses situations where liability may be averted if the accomplice's complicity is terminated prior to the commission of the crime. Model Penal Code § 2.06 cmt. 9(c) at 326 (1985). The comment notes that the actions sufficient to deprive the prior complicity of effectiveness vary with the type of accessorial behavior. Id. Relevant to the analysis here, the comment states that if 'complicity inhered in request or encouragement, countermanding disapproval may suffice to nullify its influence, providing it is heard in time to allow reconsideration by those planning to commit the crime.' Id. The comments thus indicate that in order to deprive the prior complicity of effectiveness, one who has encouraged the commission of an offense may avoid liability by terminating his or her role in the commission of the crime and by making his or her disapproval known to the principals sufficiently in advance of the commission of the crime to allow them time to reconsider as well. 


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