MEMORANDUM OPINION
SCHATZ, District Judge.
In 1970, Commodore Properties, Inc. (hereafter Commodore) established a real estate subdivision known as Casa Campana in Glendale, Arizona. Ninety-five lots in Casa Campana have been sold to various individuals since 1971. In 1975 the Secretary of the Department of Housing and Urban Development (HUD) through the Office of Interstate Land Sales Registration (OILSR) began investigation of Casa Campana, discovered...
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