M.J. KELLY, J.
This controversy arose on May 20, 1976, when the Human Rights Party, through counsel Zolton Ferency, wrote a letter to Perry Johnson, Director of the Department of Corrections, requesting declaratory rulings under the Administrative Procedures Act (APA), MCLA 24.201 et seq.; MSA 3.560(101) et seq. Rulings were requested concerning the applicability of various statutes governing the administration of prisons
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