MEMORANDUM RULING
TRIMBLE, District Judge.
Currently before the court are cross Motions for Summary Judgment by Shell Offshore, Inc. and Shell Deepwater Production, Inc. ("Shell") and the Department of the Interior ("DOI") [Docs. 21 and 27 respectively].
Facts
Shell is a lessee under numerous offshore federal mineral leases that were issued by and/or administered by the Department of Interior ("DOI"), through its sub-agency, the...
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