BAUER, Chief Judge.
On October 11, 1988, the Enforcement Division of the Commodity Futures Trading Commission ("CFTC") issued a complaint against GNP Commodities, Inc. ("GNP"), defendants-appellants Norman K. Furlett and Ira P. Greenspon and two others. The CFTC charged, among other things, that Furlett and Greenspon cheated
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