Well I don't know. But if Keaton can return she can too.
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I'll be surprised if she shows up, but I hope she does. That would make up for them dropping her from Bruce's love life after Batman Returns.
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I tend to not see the joel schumacher movies as actual sequels to the tim burton movies. They were too mediocre, plus different actors. I think they should ignore those two in the new flash movie and develop his story from batman returns onwards