Boom
I got nothin'
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A few months back, Justin Kroll said that the plan was for Penguin to be the villain (or one of the villains) in Matt Reeves' Batman film, but if that plan were to change then they'd use the character in Birds of Prey instead. Since we now have confirmation that Black Mask is the main antagonist of Birds of Prey, stands to reason that Penguin is still in play for Reeves' film.
