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

Filing 247

**DEFICIENT** EXPARTE/CONSENT MOTION for Attorney Fees by Alpha Marine Services, L.L.C., Bee Mar - Bayou Bee LLC, Bee Mar - Bee Hive LLC, Bee Mar - Bee Sting LLC, Bee Mar - Bumble Bee LLC, Bee Mar - Busy Bee LLC, Bee Mar - Honey Bee LLC, Bee Mar - Queen Bee LLC, Bee Mar - Worker Bee LLC, Bee Mar Crews LLC, Bee Mar LLC, Bollinger Algiers, L.L.C., Bollinger Amelia Repair, LLC, Bollinger Calcasieu, LLC, Bollinger Fourchon, L.L.C., Bollinger Gretna, L.L.C., Bollinger Larose LLC, Bollinger Marine Fabricators, Inc., Bollinger Morgan City, L.L.C., Bollinger Quick Repair, L.L.C., Bollinger Shipyards Lockport, L.L.C., Bollinger Shipyards, Inc., Bollinger Texas City, LP, C-Innovation, L.L.C., C-Port 2 LLC, C-Port LLC, Clean Tank, LLC, Fourchon Heavy Lift, L.L.C., Gulf Ship, L.L.C., Hornbeck Offshore Services, L.L.C., Martin Holdings, LLC, Nautical Solutions LLC, Nautical Ventures, L.L.C., North American Fabricators, L.L.C., North American Shipbuilding, L.L.C., Offshore Support Services, L.L.C., Reel Pipe LLC, Sea Fluids, L.L.C., Tampa Ship, L.L.C. (Attachments: # 1 Second and Supplemental Declaration of Carl D. Rosenblum in Support of Motion to Set Amount of Attorneys' Fees and Costs)(Rosenblum, Carl) Modified on 3/23/2011 (caa, ).

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

Doc. 247

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

HORNBECK OFFSHORE SERVICES, L.L.C., Plaintiff VERSUS

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

SECTION F

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 * *

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JUDGE FELDMAN

MAGISTRATE 2 MAGISTRATE WILKINSON

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PLAINTIFFS' MOTION AND INCORPORATED MEMORANDUM TO SUPPLEMENT MOTION TO SET AMOUNT OF ATTORNEYS' FEES AND COSTS (REC. DOC. 233) NOW INTO COURT, through undersigned counsel, come Plaintiffs, Hornbeck Offshore Services, L.L.C., the Chouest Entities and the Bollinger Entities (collectively, "Plaintiffs"), which respectfully submit this Motion and Incorporated Memorandum solely to supplement, and increase by $50,578.69, the amount of attorneys' fees and costs sought in their Motion to Set Amount of Attorneys' Fees and Costs (Rec. Doc. 233). As reflected in the Second and

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Dockets.Justia.com

Supplemental Declaration submitted herewith, the additional fees and costs sought herein were incurred during the month of February 2011 and billed to Plaintiffs after filing of their initial Motion on February 18, 2011. Consequently, for the reasons already urged by Plaintiffs, these additional fees and costs should be reimbursed. Federal Defendants have agreed not to oppose filing of this supplement and Plaintiffs agree that Federal Defendants should have the right to file a response to it. WHEREFORE, Plaintiffs respectfully request that this Court award them a total of $1,185,462.80 ($1,134,884.20 plus $50,578.69) in fees and costs as reimbursement for the losses they suffered due to Defendants' civil contempt of the Court's preliminary injunctive order. Respectfully submitted,

CARL 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 23nd day of March, 2011.

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