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

Filing 248

EXPARTE/CONSENT MOTION for Leave to File Supplemental Declaration and Supplemental Appendix 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.. Motion(s) referred to Joseph C. Wilkinson, Jr. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Proposed Pleading)(Rosenblum, Carl) (Additional attachment(s) added on 3/29/2011: # 4 Notice of Manual Attachment) (caa, ).

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

Doc. 248

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

PLAINTIFFS' EX PARTE MOTION FOR LEAVE TO FILE SUPPLEMENTAL DECLARATION AND SUPPLEMENTAL APPENDIX NOW INTO COURT, through undersigned counsel, come Plaintiffs, Hornbeck Offshore Services, L.L.C., the Chouest Entities and the Bollinger Entities ("Plaintiffs"), which respectfully move the Court for leave to file a supplemental declaration and supplemental appendix in connection with their Motion to Set Amount of Attorney's Fees and Costs (Rec. Doc. 233). Plaintiffs request leave to file the supplemental declaration and supplemental appendix solely to address the time spent and expenses incurred on this matter by Jones, Walker in the month of

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February 2011, some of which had not yet been incurred and all of which had not yet been billed to Plaintiffs at the time of Plaintiffs' filing of their Motion to Set Amount of Attorney's Fees and Costs on February 18, 2011. Plaintiffs, accordingly, ask this Court to grant them leave to submit the supplemental declaration and supplemental appendix to provide the Court with appropriate evidence of the additional $50,578.69 amount they seek in connection with their Motion to Set Amount of Attorney's Fees and Costs. Federal Defendants have agreed not to oppose the filing of this supplement, and Plaintiffs agree that Federal Defendants should have the right to file a response to it. Like the previous billings of Jones, Walker and Venable, Plaintiffs further ask that their supplemental appendix, which consists of Jones, Walker's billings for February 2011, be filed into the record under seal pursuant to the Court's Order of February 10, 2011 (Rec. Doc. 231). Plaintiffs therefore respectfully request that this Court enter an order granting them leave to file a supplemental declaration and a supplemental appendix, under seal, with respect to Jones, Walker's February 2011 billings in this matter, all as set forth more fully in Plaintiffs' memorandum in support filed herewith. WHEREFORE, Plaintiffs respectfully request that this Court grant their Ex Parte Motion for Leave to File Supplemental Declaration and Supplemental Appendix, pursuant to which Plaintiffs provide evidence of an additional $50,578.69 in attorney's fees and costs incurred in the month of February 2011 and for which they seek to increase their previous request for an award of $1,134,884.20 in fees and costs by $50,578.69, for a total amount $1,185,462.89. Respectfully submitted,

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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

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 24th day of March, 2011.

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