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

Filing 173

EXPARTE/CONSENT Consent MOTION for Extension of Time to Answer re 5 Amended Complaint,,,, 130 Intervenor Complaint by Michael Bromwich, Bureau of Ocean Energy Management, Regulation, and Enforcement, Kenneth Lee Salazar, United States Department of the Interior. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order)(Collins, Brian)

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

Doc. 173

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA HORNBECK OFFSHORE SERVICES, LLC, et al. Plaintiffs, v. KENNETH LEE "KEN" SALAZAR, et al, Defendants.

CIVIL ACTION No. 10-1663(F)(2) SECTION F JUDGE FELDMAN MAGISTRATE 2 MAGISTRATE WILKINSON

DEFENDANTS' CONSENT MOTION FOR EXTENSION OF TIME TO ANSWER PLAINTIFFS' AND PLAINTIFF-INTERVENORS COMPLAINTS Defendants, Kenneth Lee Salazar, United States Department of the Interior, Michael Bromwich, and the Bureau of Ocean Energy Management, Regulation, and Enforcement, ("Defendants"), hereby file this Motion for Extension of Time to Answer Plaintiffs' and PlaintiffIntervenor's Complaints. Defendants respectfully request that Defendants' deadline to answer Plaintiffs' and PlaintiffIntervenor's complaints be extended 21 and 23 days respectively so that Defendants' Answer to both Complaints will be due October 6, 2010. As a result of these proceedings, the related proceedings in Ensco v. Salazar, Case No. 10-1941, and the related proceedings in the Fifth Circuit Court of Appeals, the parties' positions on Plaintiffs' and Plaintiff-Intervenor's allegations have largely been addressed through briefing and argument, and Defendants' answer is unlikely to assist the Court, Plaintiffs, or Plaintiff-Intervenors with the resolution of the currently pending matters before the Court. Defendants have not previously sought extensions of time to answer. The requested extension will not prejudice the parties nor delay the other proceedings in this case. Defendants have consulted with counsel for Plaintiffs and Plaintiff-Intervenor, and both have indicated that they do

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not oppose an extension of the deadline for Defendants to answer their respective complaints to October 6, 2010. Respectfully submitted this 10th day of September, 2010.

IGNACIA S. MORENO Assistant Attorney General U.S. Dept. of Justice, Env't & Nat. Resources Div. /s/ Brian Collins GUILLERMO A. MONTERO (T.A.) BRIAN COLLINS KRISTOFOR SWANSON Natural Resources Section PO Box 663 Washington, DC 20016 Tel: [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 September 10, 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

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