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

Filing 253

EXPARTE/CONSENT First MOTION for Leave to File Opposition under seal by Michael Bromwich, Bureau of Ocean Energy Management, Regulation, and Enforcement, Kenneth Lee Salazar and United States Department of the Interior. Motion(s) referred to Joseph C. Wilkinson, Jr. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order)(Piropato, Marissa) Modified on 4/20/2011 (caa, ). Modified on 4/21/2011 (car, ).

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF LOUISIANA

HORNBECK OFFSHORE SERVICES,
LLC, et al.
Plaintiffs,
and

CIVIL ACTION No. 10-1663(F)(2)
SECTION F

DIAMOND OFFSHORE COMPANY,
JUDGE FELDMAN
Plaintiff-Intervenors,
MAGISTRATE 2
MAGISTRATE WILKINSON

v.
THE CENTER FOR BIOLOGICAL
DIVERSITY, et al.,
Defendant-Intervenors,
and
KENNETH LEE "KEN" SALAZAR, et al,
Defendants.

DEFENDANTS’ MEMORANDUM IN SUPPORT OF
CONSENT MOTION FOR LEAVE TO FILE OPPOSITION TO
PLAINTIFFS’ SUPPLEMENTAL DECLARATION AND SUPPLEMENTAL APPENDIX
Defendants, Kenneth Lee Salazar, the United States Department of the Interior, Robert
Abbey, and the Bureau of Ocean Energy Management, Regulation, and Enforcement
(“Defendants”), hereby file this memorandum in support of their motion for leave to file an
opposition to Plaintiffs’ supplemental declaration and supplemental appendix (Dkt. #248).
Defendants request leave to file opposition papers to the billing records and attendant
representations in Plaintiffs’ supplemental declaration and supplemental appendix (Dkt. #248).
Defendants have conferred with Plaintiffs who do not object to the relief sought herein.

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On March 31, 2011, Plaintiffs filed their supplemental appendix, which consists of Jones,
Walker’s billings for February 2011, under seal pursuant to the Court’s Order of February 10,
2011 (Dkt. #231). Defendants therefore respectfully request that this Court enter an order
granting them leave to file their opposition papers to Plaintiffs’ supplemental declaration and
supplemental appendix under seal.
Defendants therefore respectfully request that the Court (1) give them leave to file an
opposition to Plaintiffs’ Supplemental Declaration and Supplemental Appendix; and (2)
authorize them to file their opposition any related papers thereto under seal.
Respectfully submitted this 19th day of April, 2011.

IGNACIA S. MORENO
Assistant Attorney General
U.S. Dept. of Justice, Env’t & Nat. Resources Div.
/s/ Marissa Piropato
GUILLERMO A. MONTERO (T.A.)
BRIAN COLLINS
KRISTOFOR SWANSON
MARISSA PIROPATO
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 April 19, 2011, I caused a copy of the foregoing and its
attachments to be served through the Court’s CM/ECF System to all parties.

s/ Marissa Piropato
Marissa Piropato

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