* Associate Editor, Cardozo Law Review. J.D., Benjamin N. Cardozo School of Law, 2020; B.S., Syracuse University, 2014. I would like to thank Professor Kate Shaw, my Note Advisor, for her guidance and insightful feedback. I would also like to thank Professor Michael Herz for his thoughtfulness in helping me navigate the agency approach for my proposal. Thank you to the editors of Cardozo Law Review, past and present, especially my Notes Editor, Raquel Wildes Genet, for her edits and enthusiasm. To my parents, Debbie and David, thank you for your infinite support and encouragement and inspiring my interest in this topic. And to my siblings, Jared and Eden, thank you for being my cheerleaders and inspiring me every day.
