OPINION
GERBER, Judge.
¶ 1 This is a consolidated appeal of several cases in which the Arizona Department of Real Estate alleged that three groups of persons or entities acted in concert to violate the state subdivision laws. The land in question is located in a wooded area outside Prescott, Arizona. During the relevant time periods, the division of land "for the purpose of sale or lease ... into four or more lots, parcels, or fractional interests"...
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