LINDSAY, District Judge:
I. BACKGROUND AND PROCEDURAL HISTORY
This case involves a telemarketing operation called American Land Liquidators ("ALL"), which solicited fees from landowners to advertise their land for sale and put them together with buyers. ALL collected more than $9,000,000 in fees from about 27,000 property owners, between June 1992 and May 1995, when the business was shut down by the government investigation. It spent less than 3% of the...
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