Case 3:17-cv-07106-SK Document 37 Filed 07/27/18 Page 1 of 46 1 XAVIER BECERRA Attorney General of California 2 NICKLAS A. AKERS Senior Assistant Attorney General 3 MICHAEL E. ELISOFON (SBN 240707) BERNARD A. ESKANDARI (SBN 244395) 4 Supervising Deputy Attorneys General AMOS E. HARTSTON (SBN 186471) 5 STEVEN D. DE SALVO (SBN 199904) Deputy Attorneys General 6 300 South Spring Street, Suite 1702 Los Angeles, CA 90013 7 Tel: (213) 269-6348 Fax: (213) 897-4951 8 Email:
[email protected] 9 Attorneys for Plaintiff the People of the State of California 10 11 IN THE UNITED STATES DISTRICT COURT 12 FOR THE NORTHERN DISTRICT OF CALIFORNIA 13 14 PEOPLE OF THE STATE OF Case No. 17-cv-07106-SK 15 CALIFORNIA ex rel. Xavier Becerra, Attorney General of California, FIRST AMENDED COMPLAINT FOR 16 DECLARATORY AND INJUNCTIVE Plaintiff, RELIEF 17 v. ADMINISTRATIVE PROCEDURE ACT 18 CASE UNITED STATES DEPARTMENT OF 19 EDUCATION and BETSY DEVOS, in her official capacity as Secretary of Education, 20 Defendants. 21 22 23 INTRODUCTION 24 1. The United States Department of Education (“ED”) is unlawfully reneging on its 25 legal commitment to provide critical, expedited debt relief to tens of thousands of students who 26 were defrauded into attending the predatory, for-profit Corinthian Colleges, Inc. (“Corinthian”). 27 ED’s unjustified failure to expeditiously discharge the entirety of these students’ invalid federal 28 loans is outrageous and immoral—and it violates the Administrative Procedure Act (“APA”). 1 First Amended Complaint for Declaratory and Injunctive Relief Case No.