KOZINSKI, Circuit Judge:
The Facts
Defendant Thomas Spiegel was the Chief Executive Officer and Chairman of Columbia Savings and Loan, a thrift institution that — like so many others — collapsed in the twilight of the 1980's. Having discovered what it believed were violations of various statutes and regulations in Spiegel's conduct at Columbia, the Office of Thrift Supervision started an administrative proceeding pursuant to 12 U.S.C. §...
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