Opinion for the Court filed by Senior Circuit Judge COFFIN.
COFFIN, Senior Circuit Judge:
This case concerns a decision of the Department of Housing and Urban Development (HUD) to debar Carroll Kisser, a former employee of DRG Funding Corporation (DRG), from participating in primary and lower tier covered transactions "throughout the executive branch of the Federal Government," see 24 C.F.R. §§ 24.200, 24.110(a), for three years ending March...
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