Hornbeck Offshore Services, L.L.C. v. Salazar et al

Filing 135

Request/Statement of Oral Argument by All Defendants regarding 125 MOTION to Dismiss Case MOTION to Stay (Collins, Brian)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA HORNBECK OFFSHORE SERVICES, LLC, et al. CIVIL ACTION No. 10-1663(F)(2) Plaintiffs, SECTION F v. JUDGE FELDMAN KENNETH LEE "KEN" SALAZAR, in his official capacity as Secretary, United States Department of the Interior; UNITED STATES DEPARTMENT OF THE INTERIOR; MICHAEL R. BROMWICH, in his official capacity as Director, Bureau of Ocean Energy Management, Regulation, and Enforcement; and BUREAU OF OCEAN ENERGY MANAGEMENT, REGULATION, AND ENFORCEMENT, Defendants. MAGISTRATE 2 MAGISTRATE WILKINSON

REQUEST FOR ORAL ARGUMENT Pursuant to Local Rule 78.1E, Defendants, Kenneth Lee Salazar, United States Department of the Interior, Michael R. Bromwich, and the Bureau of Ocean Energy Management, Regulation, and Enforcement, ("Defendants"), hereby respectfully request oral argument on July 28, 2010, on their Motion to Dismiss Plaintiffs' Complaint or, in the Alternative, for a Stay of Proceedings Pending Circuit Court's Decision on Defendants' Motion to Vacate the Preliminary Injunction ("Motion to Dismiss"). Defendants filed their Motion to Dismiss on July 12, 2010. Dkt. #125. Plaintiffs filed their Response in Opposition to Defendants' Motion to Dismiss (the "Response") on July 20,

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2010. Dkt. #134. The Motion to Dismiss and the Response raise a number of complex issues regarding this Court's jurisdiction over Plaintiffs' claims in light of the rescission of the May 28 suspension orders and the issuance of the July 12 suspension orders. The resolution of these issues could be dispositive of Plaintiffs' claims. As a result, Defendants believe that oral argument is warranted in order to facilitate a full and fair consideration of the issues.

Dated: July 20, 2010

IGNACIA S. MORENO Assistant Attorney General Environment and Natural Resources Division/s/ Brian Collins GUILLERMO A. MONTERO (T.A.) BRIAN COLLINS KRISTOFOR SWANSON U.S. Department of Justice Environment and Natural Resources Division Natural Resources Section PO Box 663 Washington, DC 20016 Tel: [phone] Fax: [phone] PETER MANSFIELD Assistant United States Attorney Eastern District of Louisiana Hale Boggs Federal Building 500 Poydras Street, Suite B-210 New Orleans, Louisiana 70130 Tel: [phone]

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CERTIFICATE OF SERVICE I hereby certify that on July 20, 2010, I caused a copy of the foregoing to be served through the Court's CM/ECF System to all parties. /s/ Brian Collins Brian Collins Attorney for Defendants

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