It seems the "time between violations" is a bit of a moving target. I've seen 5 minutes apart upheld and I've seen 2 hours apart dismissed. Regardless of what their current "rule" is, it seems the ALJ's have a lot of leeway to do whatever they want. (Which is why I am consistently astonished at how some people act like complete a-holes as soon as they sit down. If I can hear you yelling from down the hallway, you don't have to be psychic to know you're probably going to lose the argument).