84 (3d Cir.1999) ("[W]hen parents unilaterally withdraw their children from public school, absent mitigating circumstances, they are not entitled to reimbursement for private school tuition until they request review proceedings.”) (citing Bernardsville Bd. of Educ. v. J.H., 42 F.3d 149, 156-58 & n. 14 (3d Cir.1994)); Marissa F. v. The William Penn Sch. Dist., 2005 WL 2304738, at *5 (E.D.Pa. Sept. 20, 2005) (barring plaintiffs from receiving reimbursement for any time student was in private school before their request for due process). 16 . Although not clear, to the extent the State is arguing that Loveland was inappropriate because it did not meet the IDEA’S requirements, the argument fails. See Florence Cnty. Sch. Dist. v. Carter, 510 U.S. 7, 13, 114 S.Ct. 361, 126 L.Ed.2d 284 (1993) (<HOLDING>); Warren G., 190 F.3d at 84 (rejecting argument
holding that section 12a2 did not apply to a private placement memorandum which was subject to a section 42 exemption recognizing that parents seeking an alternative placement may not be subject to the same mainstreaming requirements as a school board but concluding that the ideas mainstreaming requirement remains a consideration that bears upon a parents choice of an alternative placement and may be considered by the hearing officer in determining whether the placement was appropriate holding that when a private placement of securities purported to be exempt under rule 506 rjegardless of whether the private placement actually complied with the substantive requirements of regulation d or rule 506 the securities sold to plaintiffs are federal covered securities because they were sold pursuant to those rules holding that protective placement statute unconstitutionally deprived individuals of an automatic periodic reexamination of the need for continued protective placement holding that a private alternative placement need not meet the criteria of a fape