Congress enacted the 100-day provisions “to hasten, not foreclose, complainants’ access to a forum.” Curlee, 792 F.Supp. at 700. If the courts were to construe the 100-day limit as a jurisdictional requirement, many potential claimants would be deprived of recovery under the Act solely because of HUD’s delays. Beethoven Assoc., 843 F.Supp. at 1262; Curlee, 792 F.Supp. at 700; see also United States v. Scott, 788 F.Supp. 1555, 1559 (D.Kan.1992). Such a result would be inconsistent with the Act’s purpose, especially in consideration of the “great principle of public policy, applicable to all governments alike, which forbids that the public interests should be prejudiced by the negligence of the officers or agents to whose care they are confided.” Brock, 476 U.S. at 260, 106 S.Ct. at 1839 (<HOLDING>) (citation omitted). For the foregoing reasons,
holding that the comprehensive employment and training acts requirement that the secretary of labor shall take action within 120 days was not jurisdictional holding that because the plaintiff had not perfected service within 120 days of filing the complaint the complaint was subject to mandatory dismissal holding that the statutory requirement that a defendant serve any apportionment complaint within 120 days of the return date of the original complaint is mandatory and implicates a courts personal jurisdiction holding that 120 days notice was satisfied by 30 days work plus 90 days pay holding that the requirement that an alien appeal a removal order within 30 days is jurisdictional