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Name of Document:Respondents' Answer and Affirmative Defenses
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Name of Document:Division's Motion to Preclude Respondents' Advice of Counsel Defense and to Issue Subpoenas and Memorandum of Law in Support
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Name of Document:Declaration of Alexander Janghorbani in Suppport of Division's Motion to Preclude Respondents' Advice of Counsel Defense and to Issue Subpoenas
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Name of Document:Division's Reply Memorandum of Law in Further Support of its Motion to Preclude Respondents' Advice of Counsel Defense and to Issue Subpoenas
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Name of Document:Division's Second Motion to Preclude Respondents' Advice of Counsel Defense
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Name of Document:Respondents' Memorandum of Law in Opposition to Division's Second Motion to Preclude Reliance on the Advice of Counsel Defense
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Name of Document:Expert Report of Martin E. Lybecker
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Name of Document:Declaration of Judith Weinstock in Support of the Division's Motion for a Finding of Privilege Waiver
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Name of Document:Division's Reply Memorandum in Further Support of its Motion for a Finding of Privilege Waiver
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Name of Document:Declaration of Janna I. Berke Regarding Disclosure of the Division's Investigative Files
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Name of Document:Declaration of Harlan Protass in Support of the Eden Arc Resps' Opposition to the Division's Motion to Quash
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Name of Document:Division's Motion for a Finding of Privilege Waiver and Memorandum of Law in Support
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Name of Document:Affirmation of Harlan Protass in Support of the Respondents' Memorandum of Law in
Opposition to Division's Second Motion to Preclude Reliance on the Advice of Counsel Defense
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Name of Document:Division's Reply Memorandum of Law in Further Support of its Second Motion to
Preclude Respondents' Advice of Counsel Defense
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Name of Document:Declaration of Nancy A. Brown (In support of Division's Reply Memorandum of Law in Further Support of its Second Motion to Preclude Respondents' Advice of Counsel Defense)
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Name of Document:Letter dated 11/15/16 from Respondents to Administrative Law Judge in response to Division's reply memorandum in further support of second motion to preclude advice of counsel defense
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Name of Document:The Eden Arc Respondents' Memorandum of Law in Opposition to the Division of
Enforcement's Motion for a Finding of Privilege Waiver
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Name of Document:Affirmation of Harlan Protass in Support of The Eden Arc Respondents' Memorandum of Law in Opposition to the Division of Enforcement's Motion for a Finding of Privilege Waiver
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Name of Document:Division's Memorandum of Law in Opposition to Respondent's Motion for Leave to Move for Summary Disposition
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Name of Document:The Eden Arc Resps' Memorandum of Law in Further Support of their Motion for Reconsideration of this Court's "Order on Privilege Waiver"
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Name of Document:Letter dated 12/1/16 from Division to ALJ Patil, apprising the court of matters relevant to Respondent's Motion for Reconsideration of the Order on Privilege Waiver, with undesignated exhibits attached
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Name of Document:Division's Motion to Compel Respondents' Compliance with Court's 10/18, 11/10 and 12/14 Orders or to Preclude Resps from Offering Testimony or Evidence Regarding their Reliance on the Advice of Kevin Galbraith
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Name of Document:Division's Motion to compel Third Party Hinckley Allen to Comply with the Subpoena, or to Preclude Resps from Offering Testimony or Evidence Regarding their Reliance on Advice of Hinckley Allen
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Name of Document:Declaration of Nancy Brown in Support of Division's Motion to compel Third Party Hinckley Allen to Comply with the Subpoena, or to Preclude Resps from Offering Testimony or Evidence Regarding their Reliance on Advice of Hinckley Allen
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Name of Document:The Eden Arc Respondents' Memorandum of Law in Opposition to Division's Motion to Compel
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Name of Document:Divison's Memorandum of Law in Support of its Motion in Limine to Preclude Respondents from Offering Testimony or Evidence on Advice Received from Attorney Kevin Galbraith
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Name of Document:Declaration of Janna Berke in Support of Divison's Motion in Limine to Preclude Respondents from Offering Testimony or Evidence on Advice Received from Attorney Kevin Galbraith
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Name of Document:Divison's Memorandum of Law in Support of its Motion in Limine to Preclude Irrelevant Evidence & Argument Regarding Reliance on Advice of Counsel
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Name of Document:Declaration of Judith Weinstock in Support of Divison's Motion in Limine to Preclude Irrelevant Evidence & Argument Regarding Reliance on Advice of Counsel
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Name of Document:Memorandum of Law in Support of the Division's Motion in Limine to Preclude Certain Evidence and Testimony
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Name of Document:Declaration of Lindsay S. Moilanen in Support of Divison's Motion in Limine to Preclude Certain Evidence and Testimony
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Name of Document:Hinckley, Allen & Snyder, LLP's Objection to the Division of Enforcement's Motion to Compel
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Release Date:
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Name of Document:Division's Reply Memorandum in Further Support of its Motion to Compel Third Party Hinckley Allen to Comply w/Subpoena or to Preclude
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Name of Document:Declaration of Nancy A. Brown in Support of Division's Reply Memorandum in Further Support of its Motion to Compel Third Party Hinckley Allen to Comply w/Subpoena or to Preclude
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Name of Document:Letter dated 1/4/17 from Division to ALJ in response to letter from Mr. Protass dated 12/30/16 regarding Respondents' in camera submission ordered by the Court on 12/23/16
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Name of Document:The Eden Arc Respondents' Memorandum of Law in Opposition to Division's Motion to Compel Third Party Hinckley, Allen & Snyder LLP
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Name of Document:Affirmation of Harlan Protass in Support of The Eden Arc Respondents' Memorandum of Law in Opposition to Division's Motion to Compel Third Party Hinckley, Allen & Snyder LLP
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Name of Document:Letter dated 1/17/17 from Division to ALJ regarding its motion in limine to preclude
respondents from offering testimony/evidence/advice received from Kevin Galbraith
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Name of Document:Division's Prehearing Brief
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Release Date:
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Name of Document:The Eden Arc Respondents' Memoranum of Law in Opposition to Division's Motion in Limine to Preclude Evidence Regarding Advice of Counsel
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Name of Document:Affirmation of Harlan Protass in Support of The Eden Arc Respondents' Memoranum of Law in Opposition to Division's Motion in Limine to Preclude Evidence Regarding Advice of Counsel
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Release Date:
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Name of Document:The Eden Arc Respsondents' Memorandum of Law in Opposition to Division's Motion in Limine to Preclude Certain Evidence
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Name of Document:The Eden Arc Respsondents' Memorandum of Law in Opposition to Division's Motion in Limine to Preclude Evidence or Testimony on Advice Received from Kevin Galbraith
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Name of Document:Affirmation of Harlan Protass in Support of the Eden Arc Respondents' Memorandum of Law in Opposition to Division's Motion in Limine to Preclude Evidence or Testimony on Advice Received from Kevin Galbraith
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Name of Document:Respondents' Prehearing Brief
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Release Date:
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Name of Document:Declaration of Nancy Brown in Support of Division's Motion to Compel Respondents'
Compliance with Court's 10/18, 11/10 and 12/14 Orders or to Preclude Resps from
Offering Testimony or Evidence Regarding their Reliance on the Advice of Kevin
Galbraith
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Name of Document:Letter dated 12/20/16 from Division to ALJ enclosing and discussing privilege log sent
by Respondents' attorney in response to Division's Motion to Compel
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Name of Document:Letter dated 3/2/17 from Division to ALJ objecting to Respondents' arguments.
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Name of Document:The Parties' Factual Stipulations
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Name of Document:Division's Post-Hearing Brief
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Release Date:
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Name of Document:Letter dated 5/8/17 from Division to ALJ to bring a matter before the Court that was
disclosed to the Division
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Name of Document:Division's Supplemental Statement of Facts
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Release Date:
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Name of Document:Division's Responses to Respondents' Proposed Findings of Fact in Support of their
Inability to Pay Defense
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Release Date:
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Name of Document:Division's Post-Hearing Reply Brief
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Release Date:
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Name of Document:Division's Responses to Respondents' Proposed Findings of Fact
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Release Date:
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Name of Document:Letter dated 5/31 /17 from Division to ALJ objecting to Resps' motion to admit Lathen's
financial disclosure form into evidence
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Name of Document:Letter dated 5/30/17 from H. Protass (Respondent's counsel) to ALJ asserting Eden
Arc's constitutional objections to the proceeding.
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Release Date:
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Name of Document:Letter dated 6/2/17 from Weinstock (SEC) to ALJ in response to Respondents'
Constitutional Objections to the Proceeding
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Name of Document:Division's Responses to Respondents' Amended Proposed Findings of Fact
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Name of Document:Respondents' Statement of Facts
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Name of Document:Letter dated 6/9/17 from division to ALJ objecting to Resp's submission of "Amended" filings
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Name of Document:Respondents' Responses and Objections to Division's Statement of Facts
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Name of Document:Respondents' Post-Hearing Brief
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Release Date:
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Name of Document:Resps' Amended Responses and Objections to Div's Statement of Facts
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Name of Document:Resps' Amended Statements of Facts
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Name of Document:Respondents' Post-Hearing Reply Brief
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Release Date:
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Name of Document:Division's Motion to Correct Manifest Errors of Fact
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Release Date:
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Name of Document:Respondent's Opposition to Division's Motion to Correct Manifest Errors of Fact
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Release Date:
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Name of Document:Respondents' Application for Recovery of Legal Fees and Expenses Pursuant to the
Equal Access to Justice Act
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Release Date:
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Name of Document:Respondent Lathen's Affirmation in Support of the Respondents' Application for
Recovery of Legal Fees and Expenses Pursuant to the Equal Access to Justice Act,
with Exhibits 1-4
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Name of Document:Respondents' Supplemental Memorandum of Law Related to Respondents' EAJA
Application, and Motion to Seal Financial Disclosures, with Exhibits 1-6
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Name of Document:Affirmation of Donald Lathen in Support of the Application for Recovery of Legal Fees and Expenses Pursuant to the EAJA, with Exhibits 1-2
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Name of Document:Respondents' Reply Memorandum of Law in Further Support of Application for Recovery of Legal Fees and Expenses Pursuant to EAJA, with Affirmation of Donald Lathen, and Exhibits 1-4
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Name of Document:Joint letter dated 1 /5/18 from the Division and Respondents to ALJ submitting the
results of their conference to the Court
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Name of Document:Letter dated 1 /5/18 from Division to ALJ in further explanation of Division's positions
set forth in the parties' joint correspondence to the Court on this Date
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Name of Document:Letter dated 1/5/18 from Respondents to ALJ in response to Division's letter of 1/5/18
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Name of Document:Letter dated 2/14/18 from Division to ALJ, requesting that Exhibits A through C of its
response to the application for fees and expenses be held under seal pursuant to
AP-5533
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Name of Document:Division's Response to Application for Fees and Expenses of Eden Arc Capital
Management LLC and Eden Arc Capital Advisers LLC, with Exhibits A-D
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Name of Document:Letter dated 3/12/18 from Division to Sec'y. Fields, containing redacted and
unredacted copy of the slide presentation used during the oral argument on 3/8/18
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Name of Document:Letter dated 3/28/18 from Division to ALJ in response to Respondents' letter dated
3/26/18
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Name of Document:Letter dated 3/26/18 from Respondents to ALJ in response to Division's PowerPoint
slide presentation
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Name of Document:Initial Decision
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Name of Document:Initial Decision On Equal Access to Justice Act Application
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Name of Document:Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933, Section 21C of the Securities Exchange Act of 1934, Sections 203(e), 203(f) and 203(k) of the Investment Advisers Act of 1940, and Section 9(b) of the Investment Company Act of 1940
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Name of Document:Notice That Initial Decision Has Become Final
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Name of Document:Order Scheduling Hearing and Designating Presiding Judge
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Release Date:
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Name of Document:Order Postponing Hearing and Scheduling Prehearing Conference
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Name of Document:Order Following Prehearing Conference
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Name of Document:Order Denying Leave for Summary Disposition
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Release Date:
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Release Number:
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Name of Document:Order Revising Procedural Schedule and Hearing Date
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Release Date:
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Name of Document:Order On Motion to Quash
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Name of Document:Order On Motion to Preclude Advice-Of-Counsel Defense
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Release Date:
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Name of Document:Order On the Division's Disclosures
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Name of Document:Order Requiring in Camera Submission
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Name of Document:Order On Privilege Waiver
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Release Date:
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Name of Document:Order Denying the Division's Second Motion to Preclude Respondents' Advice-Of-Counsel Defense
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Name of Document:Order Regarding Motion for Reconsideration
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Name of Document:Order Redesignating Presiding Judge
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Name of Document:Order Following in Camera Review of Documents Withheld by the Division
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Name of Document:Second Order Revising Procedural Schedule and Hearing Date
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Name of Document:Order Regarding Mediation
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Name of Document:Order Denying Reconsideration and Regarding Defense-Strategy Documents
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Name of Document:Third Order Revising Procedural Schedule
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Name of Document:Order Granting Joint Motion for Mediation
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Name of Document:Order Regarding the Division's Motion to Compel
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Name of Document:Clarification Order
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Name of Document:Order Regarding the Division's Motion to Compel Hinckley Allen
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Release Date:
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Name of Document:Order Following Respondents' in Camera Submission Related to Kevin Galbraith
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Release Date:
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Name of Document:Order Resolving the Division's Motion to Compel Hinckley Allen
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Name of Document:Order Revising Hearing Location
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Name of Document:Order Regarding Subpoena Directed to Joseph Ferraro
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Release Date:
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Name of Document:Order Following Final Prehearing Conference, Resolving Certain Motions, and Directing Subpoena Compliance as to Ferraro
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Release Date:
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Name of Document:Order Regarding the Division's Motion to Compel or Preclude, and Following Further in Camera Review
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Name of Document:Post-Hearing Order
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Release Date:
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Name of Document:Order On Hearing Exhibits
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Release Date:
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Name of Document:Order Granting Extension
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Release Date:
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Name of Document:Order Granting in Part Motions to Correct Hearing Transcript
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Name of Document:Order On Stipulations
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Name of Document:Order Granting Extension
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Name of Document:Order Granting Extension
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Release Date:
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Name of Document:Motion to the Commission for Extension
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Release Date:
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Name of Document:Order Granting Motion to Admit Financial Disclosure Form
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Release Date:
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Name of Document:Order Granting in Part Respondents' Motion to File Financial Documents Under Seal and Electronically
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Name of Document:Order Directing Filing Under Seal
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Name of Document:Order On Respondents' Amended Filings
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Release Date:
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Name of Document:Order On Revisions to Record Index
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Release Date:
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Name of Document:Order On Motion to Correct Manifest Errors of Fact
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Name of Document:Order Designating Presiding Judge
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Name of Document:Order On Equal Access to Justice Act Proceeding
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Release Date:
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Name of Document:Order On Conference Results and Electronic Filing
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Release Date:
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Name of Document:Order Denying Bifurcation Request and Sealing Financial Disclosures
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Release Date:
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Name of Document:Order Scheduling Oral Argument
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Release Date:
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Name of Document:Order Sealing Exhibits
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Release Date:
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Name of Document:Order Granting Extension
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Release Date:
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Name of Document:Order Sealing Submission in Part
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Release Date:
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Name of Document:Order Following Oral Argument
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Release Date:
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Name of Document:Order Regarding Slide Presentation
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Name of Document:Notice of Stay
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Release Date:
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Name of Document:Notice of Extension of Stay
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Name of Document:Notice from the Chief Administrative Law Judge
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