Case: Healthy Gulf v. Doug Burgum

COMPLAINT for Declaratory and Injunctive Relief against BUREAU OF OCEAN ENERGY MANAGEMENT, DEPARTMENT OF THE INTERIOR, DOUG BURGUM, MATTHEW GIACONA ( Filing fee $ 405 receipt number ADCDC-12086289) filed by CENTER FOR BIOLOGICAL DIVERSITY, FRIENDS OF THE EARTH, HEALTHY GULF, NATURAL RESOURCES DEFENSE COUNCIL, SIERRA CLUB. (Attachments: # 1 Civil Cover Sheet, # 2 Summons to Doug Burgum, # 3 Summons to Matthew Giacona, # 4 Summons to U.S. Department of the Interior, # 5 Summons to Bureau of Ocean Energy Management, # 6 Summons to Attorney General, # 7 Summons to U.S. Attorney)(Mashuda, Stephen) (Entered: 11/18/2025)

1 Civil Cover Sheet

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2 Summons to Doug Burgum

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3 Summons to Matthew Giacona

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4 Summons to U.S. Department of the Interior

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5 Summons to Bureau of Ocean Energy Management

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6 Summons to Attorney General

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7 Summons to U.S. Attorney

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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by HEALTHY GULF (Mashuda, Stephen) (Entered: 11/18/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by CENTER FOR BIOLOGICAL DIVERSITY (Mashuda, Stephen) (Entered: 11/18/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by FRIENDS OF THE EARTH (Mashuda, Stephen) (Entered: 11/18/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by NATURAL RESOURCES DEFENSE COUNCIL (Mashuda, Stephen) (Entered: 11/18/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by SIERRA CLUB (Mashuda, Stephen) (Entered: 11/18/2025)

NOTICE OF RELATED CASE by All Plaintiffs. Case related to Case No. 23-00604. (Mashuda, Stephen) (Entered: 11/18/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- George Torgun, Filing fee $ 100, receipt number ADCDC-12086423. Fee Status: Fee Paid. by CENTER FOR BIOLOGICAL DIVERSITY, FRIENDS OF THE EARTH, HEALTHY GULF, NATURAL RESOURCES DEFENSE COUNCIL, SIERRA CLUB. (Attachments: # 1 Declaration of George Torgun, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Mashuda, Stephen) (Entered: 11/18/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Ava Ibanez Amador, Filing fee $ 100, receipt number ADCDC-12086435. Fee Status: Fee Paid. by CENTER FOR BIOLOGICAL DIVERSITY, FRIENDS OF THE EARTH, HEALTHY GULF, NATURAL RESOURCES DEFENSE COUNCIL, SIERRA CLUB. (Attachments: # 1 Declaration of Ava Ibanez Amador, # 2 Certificate of Good Standing, # 3 Text of Proposed Order)(Mashuda, Stephen) (Entered: 11/18/2025)

SUMMONS (6) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmtm) (Entered: 11/18/2025)

Case Assigned/Reassigned

Case Assigned to Judge Amit P. Mehta. (zmtm)

NOTICE of Appearance by Rachel Carlyn Mathews on behalf of CENTER FOR BIOLOGICAL DIVERSITY (Mathews, Rachel)

MOTION to Intervene as Defendant by CHEVRON U.S.A. INC.. (Attachments: (1) Memorandum in Support, (2) Declaration of Trent D. Webre, (3) Proposed Answer, (4) Proposed Order)(Marotta, Sean)

1 Memorandum in Support

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2 Declaration of Trent D. Webre

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3 Proposed Answer

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4 Proposed Order

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NOTICE of Appearance by Sean Marotta on behalf of CHEVRON U.S.A. INC. (Marotta, Sean)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by CHEVRON U.S.A. INC. (Marotta, Sean)

NOTICE of Appearance by Dana A. Raphael on behalf of CHEVRON U.S.A. INC. (Raphael, Dana)

NOTICE of Appearance by Keenan Roarty on behalf of CHEVRON U.S.A. INC. (Roarty, Keenan)

ORDER granting Chevron U.S.A. Inc.'s [12] Motion to Intervene. Chevron U.S.A. Inc. is hereby added as Intervenor-Defendant in this matter. See the attached Order for additional details. Signed by Judge Amit P. Mehta on 12/1/2025. (lcapm2)

ANSWER to Complaint by CHEVRON U.S.A. INC..(mg)

NOTICE of Appearance by George Torgun on behalf of CENTER FOR BIOLOGICAL DIVERSITY, FRIENDS OF THE EARTH, HEALTHY GULF (Torgun, George)

NOTICE of Appearance by Ava Ibanez Amador on behalf of CENTER FOR BIOLOGICAL DIVERSITY, FRIENDS OF THE EARTH, HEALTHY GULF (Ibanez Amador, Ava)

MINUTE ORDER granting 9 Motion for Leave to Appear Pro Hac Vice. Attorney Ava Ibanez Amador is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Amit P. Mehta on 12/2/2025. (lcapm2)

MINUTE ORDER granting 8 Motion for Leave to Appear Pro Hac Vice. Attorney George Torgun is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Amit P. Mehta on 12/2/2025. (lcapm2)

NOTICE of Appearance by Sarah C. Bordelon on behalf of CHEVRON U.S.A. INC. (Bordelon, Sarah)

NOTICE of Appearance by Jared Solomon on behalf of NATURAL RESOURCES DEFENSE COUNCIL (Solomon, Jared)

NOTICE of Appearance by Shannon Boylan on behalf of All Defendants (Boylan, Shannon) (Entered: 12/08/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 11/25/2025. Answer due for ALL FEDERAL DEFENDANTS by 1/24/2026. (Torgun, George)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 11/25/2025. (Torgun, George)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. BUREAU OF OCEAN ENERGY MANAGEMENT served on 11/24/2025; DEPARTMENT OF THE INTERIOR served on 11/25/2025; DOUG BURGUM served on 11/24/2025; MATTHEW GIACONA served on 12/3/2025 (Attachments: (1) Proof of Service - Bureau of Ocean Energy Management, (2) Proof of Service - Department of the Interior, (3) Proof of Service - Matthew Giacona)(Torgun, George)

1 Proof of Service - Bureau of Ocean Energy Management

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2 Proof of Service - Department of the Interior

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3 Proof of Service - Matthew Giacona

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Devorah Ancel, Filing fee $ 100, receipt number ADCDC-12130075. Fee Status: Fee Paid. by SIERRA CLUB. (Attachments: (1) Declaration Declaration of Devorah Ancel, (2) Certificate of Good Standing, (3) Text of Proposed Order)(Mashuda, Stephen)

1 Declaration Declaration of Devorah Ancel

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2 Certificate of Good Standing

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3 Text of Proposed Order

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Irene V. Gutierrez, Filing fee $ 100, receipt number ADCDC-12132301. Fee Status: Fee Paid. by NATURAL RESOURCES DEFENSE COUNCIL. (Attachments: (1) Declaration Declaration of Irene V. Gutierrez, (2) Certificate of Good Standing, (3) Text of Proposed Order)(Solomon, Jared)

1 Declaration Declaration of Irene V. Gutierrez

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2 Certificate of Good Standing

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3 Text of Proposed Order

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MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Julia K. Forgie, Filing fee $ 100, receipt number ADCDC-12132385. Fee Status: Fee Paid. by NATURAL RESOURCES DEFENSE COUNCIL. (Attachments: (1) Declaration Declaration of Julia K. Forgie, (2) Certificate of Good Standing, (3) Text of Proposed Order)(Solomon, Jared)

1 Declaration Declaration of Julia K. Forgie

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2 Certificate of Good Standing

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3 Text of Proposed Order

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MINUTE ORDER granting 27 Motion for Leave to Appear Pro Hac Vice. Attorney Devorah Ancel is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Amit P. Mehta on 12/12/2025. (lcapm2)

NOTICE of Appearance by Devorah Ancel on behalf of SIERRA CLUB (Ancel, Devorah)

NOTICE of Appearance by Julia Kathryn Forgie on behalf of NATURAL RESOURCES DEFENSE COUNCIL (Forgie, Julia)

MINUTE ORDER granting 29 Motion for Leave to Appear Pro Hac Vice. Attorney Julia K. Forgie is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Amit P. Mehta on 12/15/2025. (lcapm2)

MINUTE ORDER granting 28 Motion for Leave to Appear Pro Hac Vice. Attorney Irene V. Gutierrez is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Amit P. Mehta on 12/15/2025. (lcapm2)

MOTION to Intervene as Defendant by AMERICAN PETROLEUM INSTITUTE. (Attachments: (1) Declaration of Holly Hopkins, (2) Proposed Order)(Beaudreau, Tommy)

1 Declaration of Holly Hopkins

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2 Proposed Order

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LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by AMERICAN PETROLEUM INSTITUTE (Beaudreau, Tommy)

ORDER granting American Petroleum Institute's [32] Motion for Leave to Intervene as a Defendant. American Petroleum Institute is hereby added as Intervenor-Defendant in this matter. See the attached Order for additional details. Signed by Judge Amit P. Mehta on 1/11/2026. (lcapm2)

NOTICE of Appearance by Daniel S. Volchok on behalf of AMERICAN PETROLEUM INSTITUTE (Volchok, Daniel)

ANSWER to Complaint by BUREAU OF OCEAN ENERGY MANAGEMENT, DEPARTMENT OF THE INTERIOR, DOUG BURGUM, MATTHEW GIACONA.(Boylan, Shannon) (Entered: 01/23/2026)

ANSWER to Complaint by AMERICAN PETROLEUM INSTITUTE.(Beaudreau, Tommy)

ORDER. Cases filed that seek review on an administrative record, as here, are exempt from the requirements of Federal Rule of Civil Procedure 26(f) and Local Civil Rule 16.3. See LCvR 16.3(b)(1). The parties therefore shall submit a proposed schedule for dispositive motions on or before February 9, 2026. Please see the attached Order for additional details. Signed by Judge Amit P. Mehta on 1/28/2026. (lcapm3)

Unopposed MOTION for Extension of Time to File a Proposed Schedule by BUREAU OF OCEAN ENERGY MANAGEMENT, DEPARTMENT OF THE INTERIOR, DOUG BURGUM, MATTHEW GIACONA. (Attachments: (1) Text of Proposed Order)(Boylan, Shannon)

1 Text of Proposed Order

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AMENDED COMPLAINT against All Defendants filed by CENTER FOR BIOLOGICAL DIVERSITY, FRIENDS OF THE EARTH, HEALTHY GULF, NATURAL RESOURCES DEFENSE COUNCIL, SIERRA CLUB.(Torgun, George)

NOTICE of Appearance by Davis Aaron Backer on behalf of BUREAU OF OCEAN ENERGY MANAGEMENT, DEPARTMENT OF THE INTERIOR, DOUG BURGUM, MATTHEW GIACONA (Backer, Davis)

ORDER granting Federal Defendants' [39] Unopposed Motion for an Extension of Time to File a Proposed Schedule. The proposed schedule for dispositive motions shall be due on or before February 19, 2026. Please see the attached Order for additional details. Signed by Judge Amit P. Mehta on 2/5/2026. (lcapm3)

Unopposed MOTION for Extension of Time to File Answer re [40] Amended Complaint by BUREAU OF OCEAN ENERGY MANAGEMENT, DEPARTMENT OF THE INTERIOR, DOUG BURGUM, MATTHEW GIACONA. (Attachments: (1) Text of Proposed Order)(Boylan, Shannon)

1 Text of Proposed Order

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MINUTE ORDER granting Federal Defendants' 43 Unopposed Motion for an Extension of Time to Respond to First Amended Complaint. Federal Defendants and Defendant-Intervenors shall respond to the First Amended Complaint on or before March 6, 2026. Signed by Judge Amit P. Mehta on 2/17/2026. (lcapm3)

Order on Motion for Extension of Time to Answer AND Set/Reset Deadlines

Joint STATUS REPORT and Proposed Briefing Schedule by All Parties by CENTER FOR BIOLOGICAL DIVERSITY, FRIENDS OF THE EARTH, HEALTHY GULF, NATURAL RESOURCES DEFENSE COUNCIL, SIERRA CLUB. (Attachments: (1) Text of Proposed Order)(Mashuda, Stephen)

1 Text of Proposed Order

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ORDER setting briefing schedule proposed in the parties' [44] Joint Status Report and Proposed Briefing Schedule. The schedule for further proceedings in this matter shall be as follows: (1) Plaintiffs' First Amended Complaint shall be due on or before February 5, 2026; (2) Federal Defendants and Defendant-Intervenors shall respond to the First Amended Complaint on or before March 6, 2026; (3) Federal Defendants shall file the Administrative Record Index on or before March 27, 2026; (4) Plaintiffs' Motion for Summary Judgment shall be due on or before April 3, 2026; (5) Defendants' Combined Opposition to Plaintiffs' Motion for Summary Judgment and Cross-Motion for Summary Judgment shall be due on or before May 8, 2026; (6) Defendant-Intervenors' Combined Opposition to Plaintiffs' Motion for Summary Judgment and Cross-Motion for Summary Judgment shall be due on or before May 22, 2026; (7) Plaintiffs' Combined Opposition to Defendants' and Defendant-Intervenors' Cross-Motion for Summary Judgment and Reply in Support of Motion for Summary Judgment shall be due on or before June 22, 2026; (8) Defendants' Reply in Support of Cross-Motion for Summary Judgment shall be due on or before July 20, 2026; (9) Defendant-Intervenors' Reply in Support of Cross-Motion for Summary Judgment shall be due on or before August 3, 2026; and (10) Plaintiffs shall file a Joint Appendix on or before August 24, 2026. Briefing regarding the appropriate remedy shall be conducted separately from the briefing of the merits. If the court rules in favor of Plaintiffs on any of their claims on summary judgment, the Parties will submit a proposed schedule for remedy briefing within seven days of the court's summary judgment ruling. Please see the attached Order for additional details and deadlines. Signed by Judge Amit P. Mehta on 2/21/2026. (lcapm3)

ANSWER to 40 Amended Complaint by AMERICAN PETROLEUM INSTITUTE.(Beaudreau, Tommy) (Entered: 03/06/2026)

ANSWER to 40 Amended Complaint by BUREAU OF OCEAN ENERGY MANAGEMENT, DEPARTMENT OF THE INTERIOR, DOUG BURGUM, MATTHEW GIACONA.(Boylan, Shannon) (Entered: 03/06/2026)

ANSWER to 40 Amended Complaint by CHEVRON U.S.A. INC..(Marotta, Sean) (Entered: 03/06/2026)

ADMINISTRATIVE RECORD CERTIFIED INDEX by BUREAU OF OCEAN ENERGY MANAGEMENT, DEPARTMENT OF THE INTERIOR, DOUG BURGUM, MATTHEW GIACONA. (Attachments: (1) Exhibit 1 - AR Index, (2) Exhibit 2 - AR Certification)(Boylan, Shannon)

1 Exhibit 1 - AR Index

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2 Exhibit 2 - AR Certification

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NOTICE and Suggestion of Mootness by DEPARTMENT OF THE INTERIOR, DOUG BURGUM, MATTHEW GIACONA (Attachments: (1) Exhibit Endangered Species Committee Order)(Backer, Davis)

1 Exhibit Endangered Species Committee Order

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MIUNTE ORDER. The parties shall file a Joint Status Report by April 15, 2026, which advises whether this matter may be dismissed as moot or, if Plaintiffs intend to challenge mootness, proposes a schedule for further proceedings. Signed by Judge Amit P. Mehta on 4/1/2026. (lcapm3)

~Util - Set/Reset Deadlines

MOTION for Summary Judgment by CENTER FOR BIOLOGICAL DIVERSITY, FRIENDS OF THE EARTH, HEALTHY GULF, NATURAL RESOURCES DEFENSE COUNCIL, SIERRA CLUB. (Attachments: (1) Memorandum in Support, (2) Declaration of Ava Ibanez Amador, (3) Exhibit A - Draft PEIS, (4) Exhibit B - EJ PEIS Comments, (5) Exhibit C - CBD PEIS Comments, (6) Exhibit D - NOIA PEIS Comments, (7) Exhibit E - Chevron PEIS Comments, (8) Exhibit F - Final PEIS, (9) Exhibit G - CBD PNOS Comments, (10) Exhibit H - Record Emails, (11) Declaration of Dale Hensley, (12) Declaration of James Reeves, (13) Declaration of Jasmine Fournier, (14) Declaration of Kenneth Saxon, (15) Declaration of Louis Skrmetta, (16) Declaration of Michael Guckian, (17) Declaration of Robert Wiygul, (18) Declaration of William Foster II, (19) Text of Proposed Order)(Torgun, George)

1 Memorandum in Support

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2 Declaration of Ava Ibanez Amador

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3 Exhibit A - Draft PEIS

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4 Exhibit B - EJ PEIS Comments

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5 Exhibit C - CBD PEIS Comments

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6 Exhibit D - NOIA PEIS Comments

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7 Exhibit E - Chevron PEIS Comments

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8 Exhibit F - Final PEIS

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9 Exhibit G - CBD PNOS Comments

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10 Exhibit H - Record Emails

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11 Declaration of Dale Hensley

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12 Declaration of James Reeves

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13 Declaration of Jasmine Fournier

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14 Declaration of Kenneth Saxon

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15 Declaration of Louis Skrmetta

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16 Declaration of Michael Guckian

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17 Declaration of Robert Wiygul

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18 Declaration of William Foster II

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19 Text of Proposed Order

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DECLARATION of Gina Trujillo in Support of Plaintiffs' Motion for Summary Judgment by CENTER FOR BIOLOGICAL DIVERSITY, FRIENDS OF THE EARTH, HEALTHY GULF, NATURAL RESOURCES DEFENSE COUNCIL, SIERRA CLUB re [51] MOTION for Summary Judgment . (Torgun, George)

Joint STATUS REPORT and Request for Additional Pages by BUREAU OF OCEAN ENERGY MANAGEMENT, DEPARTMENT OF THE INTERIOR, DOUG BURGUM, MATTHEW GIACONA. (Backer, Davis)

MINUTE ORDER. The parties' request for an additional five pages for each remaining summary judgment filing is granted. Signed by Judge Amit P. Mehta on 4/16/2026. (lcapm3)

~Util - Set/Reset Deadlines

ORDER TO SHOW CAUSE. Plaintiffs shall show cause by April 24, 2026, why this matter should not be dismissed as moot. Please see the attached Order for additional details. Signed by Judge Amit P. Mehta on 4/17/2026. (lcapm3)