MINER, Circuit Judge:
The State and City of New York (collectively "New York") petition this court to review an April 14, 1989 final decision of the United States Secretary of Education (the "Secretary") ordering repayment of $20,643,510 granted under Chapter 1 of the Education Consolidation and Improvement Act of 1981, Pub.L. No. 97-35, §§ 551-596, 95 Stat. 463-82 (the "Act").
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