CUMMINGS, Circuit Judge.
In December 1983, respondent Ronald Hlavinka initiated a reparations action before the Commodity Futures Trading Commission under Section 14 of the Commodity Exchange Act ("CEA") (codified at 7 U.S.C. § 18) against petitioners Blunt, Ellis & Loewi, Inc. and its employees, John Fromm and Peter Pfeffer, complaining that he had lost $27,500
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