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Mr. Mess, one of the Waltham victims, was also involved in amateur fighting and sometimes sparred with Tamerlan, a friend of both men told The Wall Street Journal last month.
WSJ: Tamerlan Tsarnaev Suspected in Triple Murder
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The judge ruled that Mr Gove must give each of the six authorities involved - Waltham Forest Council, Luton Borough Council, Nottingham City Council, Sandwell Council, Kent County Council and Newham Council - an "opportunity to make representations".
BBC: Gove rejects Labour criticism after High Court defeat
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Mr. Trites, 33, recalled seeing Mr. Tsarnaev at the gym about a year ago, and for the first time since the Waltham slayings.
WSJ: After Murder Suspect's Death, Probe Is Decried, Defended