MEMORANDUM OPINION
RICARDO M. URBINA, District Judge.
GRANTING IN PART AND DENYING IN PART THE PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT; GRANTING IN PART AND DENYING IN PART THE DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
I. INTRODUCTION
This matter comes before the court on the parties' cross-motions for summary judgment. In this action, brought under the Administrative Procedure Act ("APA"), 5 U.S.C. § 702, the plaintiff seeks...
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