"Roy Lucas, counsel for Roe, was aware of the unreliability of the historiography put forward by Means. Lucas received a memorandum from a colleague pointing out that Means’s conclusions “sometimes strain credibility.” The memo added: Where the important thing is to win the case no matter how, however, I suppose I agree with Means’s technique: begin with a scholarly attempt at historical research; if it doesn’t work, fudge it as necessary; write a piece so long that others will read only your introduction and conclusion; then keep citing it until courts begin picking it up. This perverts the guise of impartial scholarship while advancing the proper ideological goals."