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 Doh 4330 2012

Doh 4329 2012-2025 Form

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number 93 matter of leading age New York versus Shaw council chief judge DiFiore members of the court may it please the court judge DiFiore may I reserve a minute in rebuttal one minute you may sir the executive compensation regulations that are before the court this afternoon for review are unlike anything this institution has seen in nearly four decades not since the mid 1970s in rap versus Carey has the court seen so aggressive an expansive assertion of claimed rulemaking Authority this is not a case this is not a case where an agency on its own initiative drawing on its special technical competence expertise in a particular field fills a gap in a statutory scheme pursuant to an explicit statutory delegation counsel do you restrict your argument to exec executive compensation not to the administrative expenses my clients do your honor a challenge only the hard cap in the soft cap we don't challenge the administrative calculate its executive compensation part of administrativ

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