MEMORANDUM OPINION
KERR, District Judge.
This controversy first arose over a drawing for a noncompetitive oil and gas lease. Joseph A. Winkler (Winkler) was the first drawee for lease # W-52387. The Wyoming Office of the Bureau of Land Management (BLM) ruled that, even though Winkler was the first drawee, his entry card had to be rejected because it was stamped "J.A. Winkler Agency" and Winkler had not complied with the necessary requirements for...
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