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

Filing 168

Request/Statement of Oral Argument by All Plaintiffs regarding 167 MOTION to Enforce Judgment (Preliminary Injunction Order). (gec, )

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

Doc. 168

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

HORNBECK OFFSHORE SERVICES, * L.L.C., Plaintiff * VERSUS * * KENNETH LEE "KEN" SALAZAR, IN HIS OFFICIAL CAPACITY AS SECRETARY, UNITED STATES DEPARTMENT OF INTERIOR; UNITED STATES DEPARTMENT OF INTERIOR; ROBERT "BOB" ABBEY, IN HIS OFFICIAL CAPACITY AS ACTING DIRECTOR, MINERALS MANAGEMENT SERVICE; AND MINERALS MANAGEMENT SERVICE, Defendants * * * * * *

CIVIL ACTION NO. 10-1663(F)(2)

SECTION F

JUDGE FELDMAN * * * * * * * MAGISTRATE 2 MAGISTRATE WILKINSON

REQUEST FOR ORAL ARGUMENT Plaintiffs, Hornbeck Offshore Services, L.L.C., the Chouest Entities and the Bollinger Entities, pursuant to Local Rule 78.1E, respectfully request oral argument on September 22, 2010, on their Renewed Motion to Enforce Preliminary Injunction Order. Based on Defendant Secretary Salazar's public announcements immediately following entry of this Court's June 22, 2010 Order, Plaintiffs previously filed a Motion to Enforce Preliminary Injunction Order, which

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the Court denied "as premature." Rec. Docs. 68, 69 and 82. Since the Court's denial of the Plaintiffs' motion, Defendants have issued their promised second moratorium and have unsuccessfully sought to have this case dismissed as moot. Rec. Doc. 165. Plaintiffs

respectfully submit that their motion is no longer premature and that, given the significance of this matter, oral argument will assist the Court in resolution of the issues raised by Plaintiffs' renewed motion. Respectfully submitted,

C
ARL D. ROSENBLUM, T.A. (2083) GRADY S. HURLEY (13913) ALIDA C. HAINKEL (24114) MARJORIE A. MCKEITHEN (21767) JONES, WALKER, WAECHTER, POITEVENT, CARRÈRE & DENÈGRE 201 St. Charles Avenue, 49th Floor New Orleans, Louisiana 70170 Telephone: [phone] Fax: [phone] [e-mail] And JOHN F. COONEY (admitted Pro Hac Vice) Venable LLP 575 7th Street, N.W. Washington, D.C. 20004 Telephone: [phone] Attorneys for Plaintiffs, Hornbeck Offshore Services, L.L.C., The Chouest Entities, and The Bollinger Entities.

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CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing pleading has been served upon all parties by email or by using the CM/ECF system which will send a Notice of Electronic filing to all counsel of record, this 7th day of September 2010.

{N2199290.1}

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