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Practice. If all else fails, try the old off-the-shoulder when her arms are tucked in. If you slide it down to an area that has a smaller circumfrence (waist, in some cases), the bra won't be pulled as tightly and you'll have more leeway in your mission.
If you practice long and hard enough, you can reach a level 7 bra remover like myself. I can undo both plastic and hook types with my teeth. I can also undo it with the shirt still on very quickly, sometimes barely brushing the bra. It looks accedental, and it's pretty funny. Joey from friends is a fabled level 10, as he can unhook a bra just by looking at it.
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