MEMORANDUM OPINION
EMMET G. SULLIVAN, District Judge.
This case arises out of long-running litigation over oil and gas leases off the coast of California. Plaintiff Noble Energy ("Noble") challenges an order of the Minerals Management Service ("MMS"), an agency of the Department of the Interior, which directs Noble to permanently plug and abandon an undeveloped exploratory well. Noble asserts that this order was arbitrary, capricious, and contrary...
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