MEMORANDUM
DAVIS, District Judge.
I. INTRODUCTION
Ivy Hall Geriatric and Rehabilitation Center, Inc.("Ivy Hall"), a provider of nursing home services, has sued Donna Shalala, the Secretary of the Department of Health and Human Services, ("HHS"), Nancy-Ann Min Deparle, the Director of the federal Health Care Financing Administration, ("HCFA") (together, the "federal defendants"), and Dr. Georges C. Benjamin,
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