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

Filing 181

MOTION for Leave to File Intervention by Bobby Jindal and Louisiana State. Motion Hearing set for 10/20/2010 10:00 AM before Judge Martin L.C. Feldman. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Notice of Hearing, # 4 Proposed Pleading, # 5 Exhibit A, # 6 Exhibit B)(Dart, Henry) Modified on 9/28/2010 (caa, ).

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

Doc. 181

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

HORNBECK OFFSHORE SERVICES, LLC, Plaintiff, VS

* * * * * KENNETH LEE "KEN" SALAZAR, in, * his official capacity as Secretary, United States * Department of the Interior; * UNITED STATES DEPARTMENT OF THE * INTERIOR; ROBERT "BOB" ABBEY, in his * Official capacity as Acting Director, Mineral * Management Service; and * MINERALS MANAGEMENT SERVICE, * Defendants * * * * * * * * * * * * * * * * * * * * * * **

CIVIL ACTION NO.: 10-1663

SECTION: "F"

MAGISTRATE: "2"

MOTION TO INTERVENE The State of Louisiana, through the Louisiana Attorney General, James D. "Buddy" Caldwell, and Bobby Jindal, in his capacity as Governor of the State of Louisiana (hereinafter collectively referred to as the "State of Louisiana"), seek leave of Court to intervene in the abovecaptioned matter for the reasons set forth in the attached Memorandum in Support.

WHEREFORE, for the reasons set forth in the attached Memorandum in Support, the State of Louisiana, through the Louisiana Attorney General, James D. "Buddy" Caldwell, and Bobby Jindal,

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in his capacity as Governor of the State of Louisiana, move for leave to intervene as Plaintiffs in this action in order to assert the claims set forth in the attached proposed Complaint. The State respectfully requests that this Court grant its Motion to Intervene and permit it to file the attached Complaint. Respectfully submitted, James D. "Buddy" Caldwell Louisiana Attorney General James Trey Phillips First Assistant Attorney General Megan K. Terrell Assistant Attorney General Section Chief ­ Environmental State of Louisiana P.O. Box 94005 Baton Rouge, Louisiana 70804-9005 Tel: [phone] Fax: [phone] By: /s/ Henry T. Dart Henry T. Dart, Esq. (La. Bar # 4557) Grady J. Flattmann, Esq. (La. Bar # 29731) Henry Dart, Attorneys at Law P.C. 510 N. Jefferson St. Covington, LA 70433 Tel: [phone] Fax: [phone] Special Counsel to the Attorney General and _/s/ Allan Kanner Allan Kanner, Esq. Elizabeth B. Petersen, Esq. Rebecca J. Davis, Esq. Kanner & Whiteley, L.L.C. 701 Camp Street New Orleans, Louisiana 70130 Tel: [phone] Fax: [phone] Special Counsel to the Attorney General

and /s/ Bradley M. Marten _______ Bradley M. Marten, Esq. Linda R. Larson, Esq. Marten Law PLLC 1191 Second Avenue, Suite 2200 Seattle, WA 98101 Tel: [phone] Fax: [phone] Of Counsel, Pro Hac Vice Pending and /s/ T. Allen Usry T. Allen Usry, Esq. Usry, Weeks, & Matthews, APLC 1615 Poydras St., Ste. 12 New Orleans, LA 70112 Tel: [phone] Fax: [phone] Special Counsel to the Attorney General and /s/ E. Wade Shows E. Wade Shows, Esq. Shows, Cali, Berthelot & Walsh LLP 628 St. Louis Street Baton Rouge, LA 70802 Tel: [phone] Fax: [phone] Special Counsel to the Attorney General

CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing pleading has been electronically filed with the Clerk of court by using the CM/ECF system which will send a notice of electronic filing to all counsel of record, this, the 27th day of September, 2010.

/s/ Henry T. Dart HENRY T. DART