PER CURIAM:
Paul A. Bilzerian appeals the district court's order applying collateral estoppel in the Securities and Exchange Commission's (SEC) action to except a debt from discharge in bankruptcy. The district court found that Bilzerian's previous criminal conviction for securities fraud, combined with a civil judgment requiring Bilzerian to disgorge fraudulently obtained profits, satisfied the requirements for application of 11 U.S.C. § 523(a)(2)(A), which...
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