REASONS
ROBERT F. COLLINS, District Judge.
This action is brought by Chevron U.S.A., Inc. (hereinafter Chevron), challenging the administrative action by the Department of the Interior and the Minerals Management Service (hereinafter MMS) in assessing a civil penalty against Chevron for violations of certain provisions of an Outer Continental Shelf (hereinafter OCS) Order, issued pursuant to the Outer Continental Shelf Lands Act (hereinafter OCSLA), 43 U...
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