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Courtney has a pretty clear alibi through the phone records and the rehab clinic over 1000 miles away in California. So you'd be talking about an assassination scenario. I guess I don't understand what motive anyone would have in killing Kurt. It's made Courtney one of the most despised humans on the planet. I could see something petty over money or drugs, but there is no proof of anything being stolen.
Kurt deciding to shoot himself seems so much more likely than any other possibility I can think of.
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