Allen M. Rosenthal is an attorney whose practice involved the collection of delinquent accounts. While Rosenthal's staff includes individuals he considers employees, he also pays debt collectors whom he regards as independent contractors. Rosenthal testified that he obtained the services of the collectors primarily through newspaper advertisements. Rosenthal would train the collectors with respect to what they should say to the debtors. The collectors used Rosenthal's letterhead...
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