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FILE - In this July 14, 2015, file photo, Sandy Phillips, whose daughter Jessica Ghawi  was killed in the 2012 Aurora movie theatre massacre, displays a T-shirt memorializing the twelve people killed in the attack, outside the Arapahoe County District Court following the day of closing arguments in the trial of theater shootings defendant James Holmes, in Centennial, Colo. Their names are, left to right, top to bottom row: Alex Teves, AJ Boik, Alex Sullivan, Gordon Cowden, Jesse Childress, Jessica Ghawi, John Larimer, Jonathan Blunk, Veronica Moser-Sullivan, Rebecca Wingo, Micayla Medek, and Matt McQuinn. (AP Photo/Brennan Linsley, File)

FILE - In this July 14, 2015, file photo, Sandy Phillips, whose daughter Jessica Ghawi was killed in the 2012 Aurora movie theatre massacre, displays a T-shirt memorializing the twelve people killed in the attack, outside the Arapahoe County District Court following the day of closing arguments in the trial of theater shootings defendant James Holmes, in Centennial, Colo. Their names are, left to right, top to bottom row: Alex Teves, AJ Boik, Alex Sullivan, Gordon Cowden, Jesse Childress, Jessica Ghawi, John Larimer, Jonathan Blunk, Veronica Moser-Sullivan, Rebecca Wingo, Micayla Medek, and Matt McQuinn. (AP Photo/Brennan Linsley, File)

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