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35 points: a card

Having to wait to attack and taking a creature out of combat to crew it is too much for only two counters

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Karakas First Printed: 1994-JUN Banned: 2008-SEP Commander is a format that focuses on legendary creatures that tie together decks thematically, and Karakas is a land that can both prevent a player from having consistent access to their commander AND allow its controller to consistently save their commander from removal

Aside from a couple of bits of removal and some ramp, the main ones of note are Praetors Counsel and Triumph of the Hordes