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Specifically, the USDA complaint alleges that English; (1) Operated as a livestock market agency from January through August without registering with USDA and without obtaining an adequate surety bond as required by the P&S Act. (2) During August, issued approximately $605 in “insuffiicient funds6 checks to sixconi signors in payment for jlivestock sold by him on their behalf. The complaint further [alleges that he failed to pay these consignors, when due, the net proceeds received from the sale of their livestock. (3) During July and August, issued accounts of sale to consignors which failed to show the full, true, and correct
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