MEMORANDUM OPINION
ROBERT E. NUGENT, Chief Judge.
TABLE OF CONTENTS
I. Uncontroverted Facts ......................................................... 157 A. The Players and Persels' Debt Settlement Business Model ................... 157 B. Kinderknecht's Enrollment in Debt Settlement Plan and Retention of Persels Law Firm ........................................................ 159 C. Kinderknecht's...
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