Affirmed in part and vacated and remanded in part by published opinion. Judge MOTZ wrote the opinion, in which Judge WILKINSON joined. Judge WILLIAMS wrote an opinion concurring in part and concurring in the judgment.
OPINION
DIANA GRIBBON MOTZ, Circuit Judge.
In 1998, the Commodity Futures Trading Commission filed a complaint alleging that Esfand Baragosh was a controlling person of Noble Wealth Data Information Services and several related companies...
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