ORDER RE: CROSS-MOTIONS FOR SUMMARY JUDGMENT
RICHARD F. CEBULL, District Judge.
I. INTRODUCTION
Plaintiff Crow Tribal Housing Authority ("CTHA") brings this action against Defendant U.S. Department of Housing and Urban Development ("HUD") under the Administrative Procedure Act challenging the HUD's agency action of recouping alleged over-payments of Indian Housing Block Grants ("IHBG") to CTHA under the Native American Housing Assistance...
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