MEMORANDUM OPINION
BATES, District Judge.
Plaintiffs Capital Area Immigrants' Rights Coalition ("CAIR") and American Immigration Lawyers Association ("AILA"), both non-profit immigrant rights advocacy organizations, have asserted a broad challenge under the Administrative Procedure Act ("APA"), 5 U.S.C. § 701 et seq., to regulations issued by the Department of Justice ("Department" or "DOJ") establishing procedural reforms for the Board...
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