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Although a number of circuits read the 'no reference' requirement strictly, others have permitted incorporation by reference in certain limited scenarios, for example, where the referenced document is 'physically attached to the [order] itself.' State of California v. Campbell, 138 F.3d 772, 783 (9th Cir.1998); Henry Hope X-Ray Prods., Inc. v. Marron Carrel, Inc., 674 F.2d 1336, 1343 (9th Cir.1982) (holding that the district court did not err in attaching a confidential appendix to its order that set out the prohibited acts); see also Davis v. San Francisco, 890 F.2d 1438, 1450 (9th Cir.1989) (permitting reference to fire department rules 'already binding upon the officers' and where '[i]t is unlikely the officers could argue they were unaware of these rules'). See e.g., H.K. Porter Co. v. Nat'l Friction Prods. Corp., 568 F.2d 24, 27 (7th Cir.1977) (holding that incorporation by reference was a 'serious and decisive' error that precluded a finding of contempt); Consumers Gas & Oil, Inc. v. Farmland Indus., Inc., 84 F.3d 367, 371 (10th Cir.1996) (strictly construing the 'no-reference' requirement of Rule 65(d)); Seattle-First Nat'l. Bank v. Manges, 900 F.2d 795, 799-800 (5th Cir.1990) (same); Thomas v. Brock, 810 F.2d 448, ...

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