WILLIAMS, Circuit Judge.
This case concerns dozens of failed investment deals orchestrated by August C. Ghilarducci, president and owner of Westchester Financial Associates, Inc. ("WFA"), at times with the assistance of his co-defendant Ronald J. Richardson. Ghilarducci and Richardson executed a series of deals in which they charged WFA clients fees for procuring Confirmation of Funds ("COF") letters from financial institutions. The letters purported to show that...
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