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Originally Posted by Drakyrias
I think that was just the movie, and doesn't classify as a patron since Lucifer isn't really willing to do stuff for him.
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Yeah, that's why I mentioned Unwilling. It's an Ally limitation by RAW, but I think it can be generalised to Patron. It doesn't make a complete write-up, but it's a start.
Did he have any special protection in the TV series? I don't properly recall much about it.