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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF LOUISIANA LAKE CHARLES DIVISION EXXON MOBIL CORPORATION * CIVIL ACTION * NO: * vs. * * DIVISION: KENNETH SALAZAR, SECRETARY, UNITED * STATES DEPARTMENT OF THE * SECTION: INTERIOR; ROBERT S. MORE, DIRECTOR * OFFICE OF HEARINGS AND APPEALS; * MICHAEL R. BROMWICH, DIRECTOR, * BUREAU OF OCEAN ENERGY * MANAGEMENT, REGULATION * AND ENFORCEMENT * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF NOW INTO COURT, through undersigned counsel, comes plaintiff Exxon Mobil Corporation (“ExxonMobil”) to allege as follows and to seek the relief set forth below. 1. ExxonMobil seeks judicial review of a final decision by the United States Department of the Interior (“DOI” or “Interior”) canceling three valuable offshore federal oil and gas leases and depriving ExxonMobil of the right to produce a reservoir believed to hold billions of barrels of oil. In refusing to grant ExxonMobil a suspension of production necessary to maintain these leases, Interior retroactively applied new legal standards, departed from established agency practices, and singled out ExxonMobil for unprecedented adverse treatment. Interior’s decision Case 2:11-cv-01474 Document 1 Filed 08/12/11 Page 1 of 27 PageID #: 1

UNITED STATES DISTRICT COURTfiles.courthousenews.com/2011/08/15/Exxon.pdf · UNITED STATES DISTRICT COURT ... contradicts the Outer Continental Shelf Lands Act and Interior’s own

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