MEMORANDUM-DECISION AND ORDER
SCULLIN, District Judge.
Introduction
This is an action seeking judicial review of an administrative agency decision under the Higher Education Act ("HEA"), 20 U.S.C. § 1001 et seq., the Administrative Procedure Act ("APA"), 5 U.S.C. § 500 et seq., and the Due Process Clause of the Fifth Amendment to the United States Constitution. The Plaintiff is a private post-secondary educational institution with campuses...
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