III. Discussion

CPSD provided evidence on 30 moves. Each move is listed chronologically in Attachment A with the date of the move, whether it was included in the criminal proceeding, a summary of the allegations, and the current status. In Attachment B, each move is discussed in detail and any ordered actions set forth. Although the individual resolutions are important, our decision today will focus on Mr. Move's overall operations and compliance with law and Commission regulations. In the discussion below, we will address major compliance issues and fashion comprehensive remedies.

In 1977, this Commission adopted General Order (GO) 142 which required carriers of used household goods to provide "capable help":

2. Capable Help

The GO prohibits carriers from allowing employees to go on duty under the influence of intoxicants or to consume intoxicants while on duty. Carriers must also provide properly maintained, clean motor vehicles of the appropriate size for the requested move. If not, the carrier is prohibited from charging drive time for any excess vehicle equipment.

CPSD witness Smith testified that Mr. Move failed to provide capable help and offered descriptions of 19 moves to support the allegation.

In response to CPSD's allegations, Mr. Move conceded historic violations of this requirement and identified its failure to adhere to this requirement as one of the "root causes" of its overall deficiencies: "The Company concedes that its employee training, oversight, and supervision were not up to its own or the Commission's standards during 2003 and 2004 and further agrees that deficiencies in these areas are among the root causes of its customer service and documentation problems during that period."

Mr. Move goes on to explain that since 2003 and 2004 it has identified and dealt aggressively with its training and supervision deficiencies. It concludes that "while there were admittedly problems in this area" it has "already taken appropriate measures to address these problems."

We agree that Mr. Move has correctly identified the root cause of most of its customer service and regulatory compliance difficulties. The record in this proceeding shows that these difficulties peaked in 2003, but that instances persist.

Mr. Move's president testified at the reopened hearing in March 2006 that since the close of the September 2005 hearings Mr. Move had completed about 3,500 to 4,000 moves and received eight serious complaints about those moves. Of those eight, five had been resolved by the time of the reopened hearings. He also testified that hiring standards and compensation have been improved. Mr. Move now seeks employees with household goods carrier experience and performs criminal records checks.

We are satisfied that Mr. Move is making progress towards resolving its failure to provide capable help and prepare documents that comply with Commission requirements. The on-going criminal stipulation and probation, coupled with this proceeding, have provided Mr. Move an incentive to direct its corporate attention and resources to these issues. In structuring our remedies in today's decision, one of our goals will be to maintain this incentive.

CPSD stated that Mr. Move's permit was suspended December 24, 2002, for failure to maintain cargo insurance, and reinstated on January 23, 2003. CPSD witness Smith testified that respondent made five moves during this period of suspension. The permit was also suspended December 24, 2004, for failure to maintain cargo insurance, and reinstated February 17, 2005. CPSD witness Zundel testified that Respondent made 1,093 intrastate moves during that suspension period.

In addition to the 85 days of suspension accounted for above, CPSD witness Smith added 18 days for failing to have proof of public liability and property damage insurance on file from January 10, 2004, through January 27, 2004. Mr. Move conceded that during the times in question it had failed to timely file the required proof of insurance. During the times Mr. Move's permit was suspended for failure to file proof of insurance, however, all required insurance was in effect but proof thereof had not been timely filed with the Commission.

In mitigation, Mr. Move explained that it had mistakenly assumed that its insurances agents would timely, and without further action on Mr. Move's part, file the required proofs of insurance. Mr. Move now understands that in addition to securing the required insurance, it must also ensure that the proof is on file with the Commission.

We find Mr. Move conducted operations as a household goods carrier while its permit was suspended. We include these violations in our tabulation of Mr. Move's fine.

This is one of the most serious of allegations against a household goods carrier - refusing to unload goods and demanding additional payments. Of the ten listed violations in the Order Instituting Investigation (OII), six were included in the criminal proceeding and addressed in the stipulation.3

The four other violations alleged in the OII - Budnic, Mohn, Clark, and Muro - are unclear. Budnic did not receive a not to exceed price, which is itself a violation, but which undercuts an allegation of holding goods hostage because there was no previously agreed-to price. Mohn, for reasons that are unclear, did not pay at all. Clark apparently left the moving site, and her goods were placed in storage, thus incurring additional charges. Muro's goods should have been released with her payment of substantially all charges in August 2003.

The clearest example of holding goods hostage is the Hogan move, which is in addition to those alleged in the OII. Persuasive testimony showed that Mr. Move's crew, after loading Hogan's goods, attempted to obtain a payment in addition to the previously agreed to amount, which had been paid in advance. Although this is the only clear example in the record, other factors support the conclusion that other customers were also subjected to the same violation.

First, Mr. Move had a pattern of incomplete documentation, which often did not include a clear not to exceed price. Absent a well-understood (and reasonable) upper limit, an unscrupulous crew could "increase" the price at will, particularly when customers were vulnerable, with their goods loaded on the truck.

Second, as discussed above, Mr. Move concedes inadequate training and supervision of the crews.

Under these circumstances, the preponderance of the record evidence supports a finding that Mr. Move's crews failed to release customers' goods upon payment of the agreed price. No evidence, however, supports a finding that these violations were either widespread or recent.

The testimony does not support CPSD's contention that Mr. Move routinely offered prospective customers estimates without viewing the goods to be moved. Rather, the declarations show that Mr. Move quoted hourly rates based on the number of workers.

For example, CPSD witness Smith testified that Muro was "given a verbal estimate over the telephone by Mr. Move employee Eddie Diaz." However, Muro's declaration shows only an hourly rate quotation and specifically states that no "estimate as to the number of hours the move would take" was presented. The following declarations state that each received a rate quote, not an estimate: Clark, Mohn, Budnic, Guarnieri, and Parker.

The testimony does show that Mr. Move quoted Lemus an hourly rate as well as the maximum number of hours the move would take. Carolyn Rios was quoted a price of $150, but charged $225 based on altered documents.

Therefore, we conclude that CPSD has shown two instances of improper estimates by Mr. Move.

CPSD alleged that Mr. Move did not comply with numerous documentation requirements in several moves. The allegations included failing to:

In response to these and other documentation deficiency allegations, Mr. Move explained that there have been instances where Mr. Move has not fully complied with Commission regulations but that these instances were isolated and did not reflect a systemic failure of compliance. Mr. Move stated that it is "committed to training its employees to properly and timely complete all shipping documents." To this end, Mr. Move has engaged a consulting firm that specializes in household goods carrier regulations to provide Mr. Move management guidance and employee training.

The Household Goods Carrier Act and its regulations impose many documentation requirements on carriers. The purpose of these requirements is to ensure that customers clearly understand the services to be provided and the cost. The record shows that Mr. Move had a past practice of using altered documents against customers that pay by credit card.

The testimony shows that moving workers (Guarnieri, 2003) as well as office managers (Rios, 2003) were actively involved in the creation of documents with factual misrepresentations. Mr. Move's senior management knew or should have known of these actions. Mr. Move's obligation to provide "capable help" and accurate documents includes the duty to ensure that employees are not manufacturing documentation, and to establish a workplace culture and necessary protocols to prevent such events.

While these violations are not recent, they are most serious. Mr. Move's management must take necessary steps to ensure that documents are properly and timely prepared as well as explained to customers. Attempts to manipulate documents must be prevented.

Analysis of a relatively recent move, however, suggests that Mr. Move has not yet achieved full compliance. The Sugarman move occurred in late August 2005, just before the initial hearings in this proceeding. Mr. Move's workers arrived three hours late to begin the move and, after viewing the goods to be moved and the logistical circumstances, offered a not to exceed price of $3,500, with the move completed that day. At 8:00 p.m., the movers were fatigued and the move halted for the day. The move was completed the next day after another 12 hours of work. Prior to completing the work, however, Mr. Move's crew chief required Sugarman to accept a change order with a revised not to exceed price of $7,000. In its brief, Mr. Move states that the change order was for "the additional services that would be required to complete the move the following day." The "additional services" are not identified, other than $150 for storing the loaded truck overnight.

The record does not support a conclusion that Mr. Move provided any additional services to Sugarman, other than the overnight storage, which might justify a change order doubling the not to exceed price. Having partially completed the move, Mr. Move had placed Sugarman in a vulnerable position where he had no readily available alternatives other than to accept Mr. Move's change order.

The Sugarman move illustrates that Mr. Move has not yet fully succeeded in complying with documentation requirements. We conclude, therefore, that these violations should be considered in the remedies we fashion below.

CPSD presented evidence that Mr. Move had not complied with requirements for processing loss and damage claims. Most of the claims had been resolved. The Garcia/Leon and Bernard moves were addressed in the criminal case in 2003. Similarly, the Hood damage claim of $240, where Mr. Move only offered $100, was resolved with the Commission's help in 2003, as was the King claim.

The Lemus claim, which Mr. Move asserts it did not receive, for $400 of damage to furniture is addressed in Attachments A and B to this decision.

The Clark claim remains outstanding and Mr. Move is ordered to resolve this claim and report the resolution.

In response to CPSD's allegations, Mr. Move explains that it has received few damage claims in relation to the thousands of moves it performs each year. Many of the claimants included in CPSD's testimony did not comply with the requirements for submitting a timely and valid loss or damage claim. Nevertheless, to improve overall customer service, Mr. Move has instituted an enhanced tracking and claim resolution process, with shorter timelines than required by the Commission regulations.

We find that CPSD has demonstrated that Mr. Move's processing of loss and damage claims has been deficient. We are hopeful that Mr. Move's efforts will remedy this deficiency, but we will order enhanced monitoring by CPSD to determine the success of the efforts.

CPSD witness Smith included a list of 13 telephone directories which she alleged "fail to cross reference all its fictitious business names as required by Item 88 of Max 4."

MAX 4 tariff, Item 88, Number 5 requires that in its relationships with the public each authorized household goods carrier must cross reference all listings under different names in a telephone directory: "Carriers listing more than one name in the classified section of a telephone directory shall cross reference each name to all other names listed."

Witness Smith did not testify, nor provide evidence to support, that Mr. Move had multiple advertisements in the directory under different names which were not cross-referenced. The testimony showed that not all fictitious business names used by Mr. Move were listed in each advertisement. The rule, however, does not require each carrier to list all business names, but only requires cross referencing other names listed in the same directory. Therefore, we conclude that CPSD's testimony does not support a finding of violations of this rule.

CPSD witness Smith testified that during 2004 she made three requests to inspect Mr. Move records, and that Mr. Move failed to provide timely responses. Smith's testimony references written requests relating to five separate moves submitted to Mr. Move on six different days. The testimony also includes a request for a meeting, which was ignored.

Pursuant to § 5226, Commission employees may inspect any records required to be kept by a household goods carrier:

The employees, representatives, and inspectors of the commission may, under its order or direction, inspect and examine any lands, buildings, equipment, accounts, books, records, and memoranda, including all documents, papers, and correspondence kept or required to be kept by household goods carriers.

Mr. Move does not dispute CPSD's description of its response to CPSD's information and meeting requests. Mr. Move attributes its lack of responsiveness to the then on-going criminal case in which CPSD was cooperating with the prosecution. Mr. Move contends that it is now "committed to working to ensure timely responses to all future requests for information from the Commission."

As set forth below, we find that Mr. Move's failure to allow inspection of its records in 2004 to be a serious violation, and we include it separately in tabulating Mr. Move's fine.

For the violations set out above, CPSD seeks revocation of Mr. Move's household goods carrier permit, unspecified fines, and reparations to customers. We address each remedy below.

Pursuant to § 5285, this Commission may revoke a household goods carrier permit, after notice and opportunity to be heard, "for failure to comply with any provision of the [Household Goods Carrier Act] or with any order, rule, or regulation of the commission, or with any term, condition, or limitation of the permit."

In the OII, CPSD presented the results of its investigation and formally accused Mr. Move of distinct violations of applicable laws or regulations. In its opening brief, CPSD concludes that these violations are serious and repeated, and that Mr. Move's defense of discontinuance of the unlawful operations is no defense. CPSD is convinced that Mr. Move will operate unlawfully if the Commission allows it to operate at all.

Mr. Move responds that revoking its household goods carrier permit would put 100 employees out of work and financially ruin Mr. Move's owners. Mr. Move cited Commission enforcement precedent that does not support CPSD's requested revocation.

The Commission is authorized to revoke a household goods carrier permit for violations of applicable law. Here, it is undisputed that Mr. Move has violated the laws and regulations applicable to household goods carriers. Accordingly, the Commission has the power to revoke Mr. Move's household goods carrier permit; whether the Commission should exercise that power is the question before us.

Our precedents in addressing revocation requests show that the Commission typically revokes household goods carrier permits where the carrier is a threat to public safety or has demonstrated that it is unable or unwilling to bring its operations into compliance with laws and regulations applicable to household goods carriers.

In Ace of Bace Moving Company, Decision (D.) 01-08-035, the Commission found that the record showed that Ace had a pattern of noncompliance with applicable law and regulations, and that Ace had a practice of extracting unlawful additional amounts for a move by refusing to unload household goods, "holding goods hostage." In addition, the president of Ace had failed to disclose his criminal history on his permit application, and had subsequently been convicted of driving while intoxicated. Based on the largely undisputed facts, the Commission revoked Ace's household goods carrier permit.

In contrast, where the carrier demonstrates a sincere and successful effort to bring its operations into compliance, the Commission has not revoked the household goods carrier permit. In Starving Students, D.03-11-023, the Commission found that the carrier had committed serious violations which necessitated two investigations by staff. The Commission found that the carrier had expended considerable resources and capital in an attempt to resolve its customer service issues, and, although not completely successful, had "made progress." The Commission imposed a 180-day permit suspension but stayed imposition of the suspension for a three-year probation period.

The record shows that Mr. Move has "made progress" in bringing its operations into compliance with California law and the Commission's regulations. This progress, unfortunately, was initiated by a criminal court proceeding, jail sentence, and probation, rather than an independent desire to comply with the law. The financial consequences of that enforcement effort, plus the ensuing Commission proceeding, have been incentives for making progress toward full compliance. Below, we impose certain obligations on Mr. Move to ensure future compliance incentives. We conclude, therefore, that revocation is not necessary at this time.

Mr. Move's past practices, however, have demonstrated a capacity to extract funds from customers without regard to legal or regulatory requirements. Continued regulatory monitoring of Mr. Move's operations is essential to ensure that future customers are not subjected to these past practices. We impose the following requirements:

In combination with CPSD's extant authority to supervise household goods carriers, we are confident that this enhanced monitoring will enable CPSD to quickly uncover any future violations by Mr. Move.

Pursuant to § 5311, this Commission is empowered to impose a fine of up to $1,000 per violation of law or regulations. Where a person or corporation operates as household goods carrier "without a valid permit," the Commission is authorized by § 5313.5 to impose a fine of $5,000 for each violation.5

CPSD seeks $515,000 in fines for operating with a suspended permit6, and the "maximum penalty" of $500 for each other violation found.

Mr. Move responds that CPSD's fines are excessive and unjustified, and ignore Commission-adopted guidelines for setting fines.

To provide guidance in setting fines, the Commission distilled the principles that it has historically relied upon in assessing fines and restated them such that they may form the basis for future decisions assessing fines. See Rules for Enforcement of the Standards of Conduct Governing Relationships between Energy Utilities and Their Affiliates adopted by the Commission in D.97-12-088, D.98-12-075, App. B. Those principles begin by distinguishing reparations from fines. The purpose of reparations is to return improperly collected amounts to customers. The purpose of fines, in contrast, is to deter further violations. Effective deterrence creates an incentive for household goods carriers to avoid future violations.

CPSD has not addressed how additional fines will effectively deter future violations by Mr. Move. The criminal case and stipulation, along with this proceeding, have imposed significant financial and other consequences on Mr. Move and its president for violations of the Public Utilities Code. The threat of probation revocation and possible incarceration creates a significant incentive for compliance.

In determining whether to impose a fine and, if so, at what level, the Commission's guidelines consider the severity of the offense, the utility's conduct, the financial resources of the utility, the totality of circumstances in furtherance of the public interest, and the role of precedent.

The severity of the offense includes consideration of the economic harm to customers as well as the economic benefit gained by the public utility. Here, the record shows that any significant economic gain by Mr. Move occurred, if at all, prior to the enforcement effort by the Los Angles City Attorney's office. The reparations ordered below show that the harm to customers from Mr. Move's recent violations has been modest, and we also note that the cost of defending this action is likely to have exceeded any economic gain by Mr. Move.

The record shows that the Los Angles City Attorney's office investigated and prosecuted Mr. Move for numerous criminal violations, and that the resulting stipulation required significant changes in Mr. Move's operations, including the termination of Mr. Move's president's cousin from employment at Mr. Move. The City Attorney's office has not sought to revoke Mr. Move's probation despite having been informed of the results of CPSD's on-going investigation.

The severity of the offense also includes consideration of the effects of disregarding a Commission order. Compliance and cooperation is essential to the proper functioning of the regulatory process. This factor is particularly important in consideration of Mr. Move's failure to provide requested information, which is addressed below.

The record shows, as discussed in more detail below, that Mr. Move conducts about 12,000 moves a year - the vast majority of those moves successfully complying with Commission regulations and resulting in satisfied customers. The record does not support a finding of wide-spread or systemic violations of applicable law and regulation in Mr. Move's overall operations. On the moves where Mr. Move does not successfully comply, however, the violations may be serious for those customers. Relocation is inherently stressful, and entrusting one's belongings to a third party leaves one feeling vulnerable. In this context, incompetent and possibly dishonest workers failing to provide reliable service can inflict disproportionately severe harm.

On balance, and in light of the overall circumstances of this proceeding, we find Mr. Move's violations to be limited in scope but severe to the affected customers.

The next factor is the utility's efforts to prevent, detect, and rectify the violation. In this case, Mr. Move did not prevent or detect these violations; however, Mr. Move has shown that it has made substantial efforts to rectify violations largely as a result of the criminal proceeding. We encourage Mr. Move to proactively seek out, understand, and implement applicable laws and regulations.

The next factor is the financial resources of the utility. Mr. Move has annual gross revenues of about $2 million, and, at the time of briefing, was uncertain whether there would be any net income in 2005.

The role of precedent is also important in our consideration of imposing a fine. Here, CPSD has provided us no citations to previous decisions imposing a fine on a household goods carrier that is already subject to criminal court probation requiring full compliance with household goods carrier law and regulations.

The final factor is the totality of the circumstances in furtherance of the public interest. Pursuant to the criminal case stipulation, Mr. Move has made restitution of $22,332 and paid fines and penalty assessments of $8,400. These previous payments and the criminal court probation have already elicited substantial compliance efforts and improved if still imperfect performance. On balance, we find that creating some further financial incentive for Mr. Move to continue making progress towards full compliance with applicable law and regulations is in the public interest. The payments we describe below will provide periodic reminders to Mr. Move of the importance of its on-going efforts.

As provided in § 5313.5, we are authorized to impose a fine of up to $5,000 for operating as a household goods carrier without a valid permit. CPSD has provided evidence of two periods, totaling 85 days of such operations. In mitigation, Mr. Move has provided evidence that all required insurance actually was in effect but that the proof of such insurance had not been timely filed. We also note that Mr. Move has limited financial resources. Although § 5315 would allow us to count each day as a separate violation, we will exercise our discretion and count each period as a single violation, and impose a fine of $5,000 for each violation.

Pursuant to § 5311, every household goods carrier that fails to comply with the Household Goods Carrier Act or to "comply with any order, decision, rule, regulation, direction, demand or requirement of the Commission" is "guilty of a misdemeanor, punishable by a fine of not more than $1,000 or by imprisonment in the county jail for not more than three months, or both."

CPSD does not request a specific fine for Mr. Move, but rather seeks "the maximum penalty for each violation." Mr. Move calculates the amount to be $1,329,000, based on the assumption that CPSD proves each of its alleged violations. Many of those violations, however, occurred prior to the criminal case stipulation, and some were included in the criminal case.7 As discussed above, CPSD did not prove all of the allegations, and did not provide us an analysis showing how additional substantial fines would achieve our goal of deterrence given the criminal court probation. CPSD has not explained why a fine by this agency will be a greater deterrent than the possibility of incarceration and business closure that Mr. Move currently faces pursuant to the criminal case.

As noted earlier, Mr. Move completes about 12,000 moves per year. Of those moves, about five annually have resulted in serious alleged violations of household goods carrier regulations; this represents a compliance success rate of 99.96%.

Mr. Move's vulnerability to opportunistic customers should also be acknowledged. The record contains several requests by customers for payments greatly in excess of any amounts warranted under the applicable regulations. Mr. Move also contends that customers have threatened to use the criminal case as a means of retaliating against Mr. Move for legitimate charges. We find that the usual purpose of fines, deterrence, will not be served by imposing an additional fine anywhere near the amount sought by CPSD.

The record shows, however, that Mr. Move has instances of current noncompliance. To prevent such lapses in the future, we order compliance monitoring by CPSD of Mr. Move's operations. As described in more detail below, we also create a financial incentive to impress upon Mr. Move the necessity of complying with Commission regulations and cooperating with Commission staff. In light of the unique circumstances of the case, we will select only the most egregious and proven violations on which to base our fine calculation.

The Sugarman move is recent and illustrates both failure to provide competent help to prepare an accurate not to exceed price and charging in excess of a not to exceed price. The Hogan move demonstrated holding goods hostage, and the Rios move included altered documents. We impose the statutory maximum of $1,000 per violation for each of these moves.

Timely response to Commission staff's requests for information are essential to this agency discharging its duties to oversee the operations of its regulatees. Mr. Move's admitted violations of failing to respond to our staff's requests are serious, and we impose the maximum fine of $1,000 for each of the three violations identified by CPSD.

Thus, in today's decision we impose further fines of $16,000 on Mr. Move. The fines are summarized below.

Name

Violation

Fine

 

Failure to respond to commission staff request for information

3 x $1,000
= $3,000

 

Operating while permit suspended

2 x $5,000
= $10,000

Sugarman

Charges greater than not to exceed price

$ 1,000

Hogan

Holding Goods Hostage

$ 1,000

Rios

Altered Documents

$ 1,000

 

    TOTAL

$ 16,000

Consistent with our past practice, we will suspend $12,000 so long as Mr. Move complies with California law and regulations applicable to household goods carriers. Should any further violations be proven, the $12,000 shall become immediately due and payable.

The remaining $4,000 shall be paid in four installment of $1,000 each, with the first payment due 90 days after the effective date of this order. The three subsequent payments shall be due in 90 days intervals thereafter. Mr. Move's president shall demonstrate to the CPSD Director in their quarterly meeting that payments have been made on schedule. Failure to adhere to the schedule shall render the full amount, $16,000, immediately due and payable.

In Attachment B, we set out the following refund obligations:

Lemus $400

Rios $75

Guarnieri $200

Parker $2,701.94

Sugarman $1,953.24

No later than 25 days after the effective date of today's decision, Mr. Move shall file and serve a compliance filing showing that all refunds have been paid.

We also order Mr. Move to evaluate, consistent with applicable regulations, the loss and damage claims from Malloy and Clark. No later than 45 days after the effective date of this order, Mr. Move shall file and serve a compliance filing showing that these claims have been resolved as provided in our regulations.

Mr. Move has on occasion tolerated deception, employee incompetence, and indifference to customers. The record suggests, however, that the criminal proceeding initiated by the Los Angeles City Attorney's office has elicited substantial efforts by respondents to reform their operations and comply with the Commission's regulations and California law. As the more recent complaints show, operations are not yet perfect.

Mr. Move is instructed to continue to improve hiring practices to ensure that it hires only experienced and trustworthy employees who meet the requirement of "capable help." Increased compensation and incentives for high quality employees should be used.

Management is responsible for planning work schedules such that employees are not overly fatigued. Management should also take care not to overschedule. Clear communication with customers is essential to setting reasonable expectations that Mr. Move's workers can meet. Accurate and timely documentation is an essential component of successful customer communication.

Loss and damage claims should be handled quickly and fairly. Expert customer service representatives may be needed to handle what Mr. Move describes as "hypersensitive" customers.

In conclusion, we admonish the officers and management of Mr. Move for past performance but acknowledge their improvement. The objective of the enhanced supervision and financial incentives ordered in today's decision is to bring all of Mr. Move's operations into full compliance.

3 Jones, Garcia/Leon, Arico, Barnett Lewis, Lussier, Jin Lee.

4 The CPSD Director is authorized to require additional meetings as necessary to determine whether Mr. Move is in compliance.

5 Section 5313.5 also provides that the Commission may recover "the reasonable expense of investigation incurred by the Commission." This remedy is limited to operating without a valid operating permit, and does not extend to the costs of investigating other violations of the Household Goods Carrier Act. Here, the costs of investigating these particular violations are nominal because the Commission's own records disclose the permit suspension and Mr. Move did not deny that it operated during those times. CPSD, however, seeks recovery of its investigation costs for all violations. We deny this request because recoverable costs are nominal.

6 103 days x $5,000/day = $515,000.

7 Mr. Move asserts that the Commission may not impose additional sanctions for moves at issue in the criminal proceeding, and CPSD disagrees. We need not and do not reach that question here, but rather rely only on cases arising outside of the criminal proceeding as the basis for today's decision.

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