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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Section 888

Citation
Section 888
Parent Document
Open Cmtys. Alliance v. Carson, 286 F. Supp. 3d 148 (2017)
Effective Date
2017-12-23

Other Sections in This Document (99)

Full Text

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In sum, the significant differences between the (1) pilot and Rule-affected PHAs, (2) selection criteria HUD used to identify each group, and (3) purposes HUD sought the demonstration project and Rule to achieve impose on HUD a burden to show that any conclusions the Interim Report extrapolated from the demonstration project's findings apply to the specific Rule-affected areas. Neither the Suspension Memo nor Letter to PHAs, however, even attempt to make such a showing. Nor, for that matter, does the defendants' briefing. The plaintiffs thus have established likely success on the merits of their notice and comment claim.