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 Att. 1

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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SECOND AND SUPPLEMENTAL DECLARATION OF CARL D. ROSENBLUM IN SUPPORT OF MOTION TO SET AMOUNT OF ATTORNEYS' FEES AND COSTS Pursuant to 28 U.S.C. §1746, I, Carl D. Rosenblum, declare under penalty of perjury that the foregoing is true and correct: 1) My name is Carl D. Rosenblum. I am a senior partner with Jones, Walker,

Waechter, Poitevent, Carrère & Denègre L.L.P. ("Jones Walker"). I am lead counsel of record in the above captioned case for Plaintiffs, Hornbeck Offshore Services, L.L.C., the Chouest Entities

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and the Bollinger Entities (collectively, "Plaintiffs"). I am over the age of majority and have never been convicted of a felony or a crime of moral turpitude. I am competent and qualified to make this Declaration. The statements contained in this Declaration are true and correct based upon my personal knowledge and documents created and maintained by Jones, Walker in the ordinary course of business. 2) I previously submitted a declaration in support of Plaintiffs' Motion To Set

Amount Of Attorneys Fees and Costs (Rec. Doc. 233). This Declaration is intended as a supplement to that previous declaration which is not repeated here but is incorporated by reference. 3) The sole purpose of this Declaration is to address time spend and expenses

incurred on this matter by Jones, Walker attorneys and paralegals in the month of February 2011, which is not covered in the original declaration and its attachments. 4) For the month of February 2011, I have personal knowledge of and/or have I have personal

supervised the work performed by Jones, Walker personnel on this case.

knowledge of the purpose of the work and whether it was performed in an efficient manner. 5) In preparation for making this Declaration, I reviewed Jones, Walker's February

2011 bills related to this matter to assess its reasonableness and necessity and its relationship to the Court's Contempt Order (Rec. Doc. 226). 6) As reflected on the Supplement Appendix which is filed under seal

contemporaneously herewith, most of the time related to reviewing the individual time and expense entries to evaluate whether there was anything in the entries that needed to be redacted or was unrelated to the Court's Contempt Order.

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