JOHNSON, Presiding Judge.
This case arises from a criminal investigation by the State of Georgia's Office of the Commissioner of Insurance ("the Commissioner") into the business practices of National Viatical, Inc., Explore Financial Group, Inc., NVT Trust, James Torchia, and Michael Sullivan. Torchia and Sullivan are the CEO and CFO of National Viatical, Inc. Sullivan owns Explore Financial Group, which acted as a marketing company for National Viatical, Inc.
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