Exile Phoenix, then return it to the battlefield (front face up)
If it was cast by Garruk's controller, he or she can choose which one stays and which one goes to the graveyard.) (Note that as Clone enters the battlefield as a copy of Garruk, it will have 3 loyalty counters, because that's a property of the Garruk card.) It was possible to have Clone remain on the battlefield even under the old rules, but it required a much more contrived set of circumstances
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