When you want to add a footnote in a legal memo, do you put it after the citation?

It depends on the structure of the sentence. If the footnote is from the totality of the sentence, then I would footnote at the end of the sentence. If you are going to quote or cite additional info from the case, then right after the citation. Hope that helps.When you want to add a footnote in a legal memo, do you put it after the citation?
A citation is a footnoote, so I'm not sure what you mean.

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