FLAUM, Circuit Judge.
In 1974, the City of Gary, Indiana received a $2,060,613 grant from the Department of Labor pursuant to the Comprehensive Employment and Training Act (CETA). The Department in 1974 and 1975 audited the City's use of the funds and reported that almost $1,000,000 had been misspent and therefore would be recoverable by the Department. After subsequent audits and various other proceedings, the matter was placed before an administrative law judge...
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