ORDER
DONALD E. O'BRIEN, Senior District Judge.
This matter comes before the Court upon what has been designated by the litigants as plaintiff's motion for summary judgment (Docket No. 7) and defendant's cross motion for summary judgment (Docket No. 18). However, it is really before the Court under the Administrative Procedure Act as an appeal. After careful consideration of the parties' written briefs and oral arguments, as well as the relevant case law...
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