The following excerpt is from Underhill v. Hernandez, 65 F. 577 (2nd Cir. 1895):
The acts of the defendant, as a military commander of the revolutionary forces in the civil war in Venezuela, although performed before the revolution became successful, are sheltered by the same immunities that would surround them if they had been performed subsequently. The organization, of which he was a part, represented that kind of a de facto government which is described in Williams v. Bruffy:
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