re: Trump owes lenders $450 million yet there were no complaints from the lenders.

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It has seldom been used

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The law, often referred to by its shorthand, 63(12), which stems from its place in New York’s rule book, is a regulatory bazooka for the state’s attorney general, Letitia James. Her office has used it to aim at a wide range of corporate giants: the oil company Exxon Mobil, the tobacco brand Juul and the pharma executive Martin Shkreli.

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That might seem unusual, but under 63(12), such evidence was not necessary to find fraud.

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