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

Filing 15

MOTION to Continue the June 21, 2010 Preliminary Injunction Hearing by Robert Abbey, Minerals Management Service, Kenneth Lee Salazar, United States Department of the Interior. Motion Hearing set for 7/28/2010 10:00 AM before Judge Martin L.C. Feldman. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Notice of Hearing)(Smith, Sharon)

IN THE UNITED STATES DISTRICT COURT F O R THE EASTERN DISTRICT OF LOUISIANA H O R N B E C K OFFSHORE SERVICES, LLC, C I V I L ACTION No. 10-1663(F)(2) Plaintiff, S E C T IO N F v. J U D G E FELDMAN K E N N E T H LEE "KEN" SALAZAR, in h is official capacity as Secretary, United S t a te s Department of the Interior; R O B E R T "BOB" ABBEY, in his official c a p a c ity as Acting Director, Mineral M a n a g e m e n t Service; and MINERALS M A N A G E M E N T SERVICE, D e f e n d a n t s. M A G IS T R A T E 2 M A G I S T R A T E WILKINSON

DEFENDANTS' MOTION FOR CONTINUANCE OF JUNE 21, 2010 HEARING ON PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION

NOW COMES, the Defendants in the captioned case and, for the reasons more fully set forth in the accompanying memorandum respectfully urge the Court to reconsider its June 11, 2010 order scheduling Plaintiffs' Motion for Preliminary Injunction for June 21, 2010 and the associated briefing deadline of June 16. Defendants request that the Court maintain the July 28, 2010 hearing date contained in Plaintiffs' Notice of Hearing. As an accommodation to Plaintiffs' concerns for expediency, Defendants request, consistent with Plaintiffs' suggestion, that the Court address both the request for preliminary and permanent relief in a combined proceeding. Defendants therefore

propose that the July 28 hearing include a full hearing on the merits of Plaintiffs' claims in accordance with Fed. R. Civ. P. 65(a)(2). This would achieve Plaintiff's objective of expediting review, it would resolve the entire case quickly, and would insure adequate opportunity for comprehensive briefing of the important safety, economic, and environmental issues before the Court. A memorandum of points and authorities accompanies this motion as does a proposed order for the Court's consideration. Dated: June 11, 2010 Respectfully Submitted, JIM LETTEN UNITED STATES ATTORNEY /s / SHARON D. SMITH SHARON SMITH (La. Bar No. 17146) Assistant United States Attorney Eastern District of Louisiana Hale Boggs Federal Building 500 Poydras Street, Suite B-210 New Orleans, Louisiana 70130 Tel: [phone] IGNACIA S. MORENO Assistant Attorney General Environment and Natural Resources Division /S/GUILLERMO MONTERO GUILLERMO MONTERO (T.A.) BRIA N COLLINS U.S. Department of Justice Environment and Natural Resources Division Natural Resources Section PO Box 663 Washington, DC 20016 Tel: [phone] Fax: [phone] ATTORNEYS FOR DEFENDANTS