LYNCH, Circuit Judge.
Al Rizek was a vice president of PaineWebber Incorporated of Puerto Rico. Over a ten-month period in 1993 he churned the accounts of five customers, causing losses of approximately $195,000 on accounts with average balances that totaled about $700,000. This violated Section 10(b) of the Securities Exchange Act of 1934, 15 U.S.C.
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