LITTLE, District Judge:
I. Procedural History
In December of 1997, the Office of Inspector General ("OIG") for the Department of Health and Human Services ("HHS") completed an investigative audit report of four grants awarded by HHS to the Delta Foundation ("Delta") in 1991, 1993, 1994 and 1995 under the Community Services Block Grant program. On the basis of the audit report, the Administration of Children and Families ("ACF") within the HHS issued...
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