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

Filing 276

MOTION Entry of Final Judgment 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 set for 8/10/2011 10:00 AM before Judge Martin L.C. Feldman. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission, # 3 Proposed Order)(Rosenblum, Carl)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
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HORNBECK OFFSHORE SERVICES, L.L.C., )
et al.
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Plaintiffs,
)
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VERSUS
)
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KENNETH LEE “KEN” SALAZAR, IN HIS
)
OFFICIAL CAPACITY AS SECRETARY,
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UNITED STATES DEPARTMENT OF
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INTERIOR; UNITED STATES
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DEPARTMENT OF INTERIOR; ROBERT
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“BOB” ABBEY, IN HIS OFFICIAL
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CAPACITY AS ACTING DIRECTOR,
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MINERALS MANAGEMENT SERVICE;
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AND MINERALS MANAGEMENT
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SERVICE,
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Defendants.
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)

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

Section F
Judge Martin L. C. Feldman

Magistrate 2
Magistrate Joseph C. Wilkinson, Jr.

MOTION FOR ENTRY OF FINAL JUDGMENT
NOW INTO COURT, through undersigned counsel, come Plaintiffs, Hornbeck Offshore
Services, L.L.C., the Chouest Entities and the Bollinger Entities, which file this Motion for Entry
of Final Judgment pursuant to Rule 58 of the Federal Rules of Civil Procedure. As set forth
more fully in the Memorandum filed in Support of this Motion, the history of this case, its
current procedural posture, and the current factual context of the original dispute between the

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parties justifies that the Court’s prior Order dated February 2, 2011 on Plaintiffs’ Motion for
Recovery of Attorney’s Fees (Rec. Doc. 226) and its prior Order dated June 23, 2011 on
Plaintiffs’ Motion to Set Amount of Attorney’s Fees (Rec. Doc. 275 (revising and adopting as
revised the United States Magistrate Judge’s Findings and Recommendation (Rec. Doc. 265))
should be made final so that the time for filing a notice of appeal on either or both Orders shall
commence and so that all other claims between the parties should be dismissed with prejudice.
Given that Plaintiffs are the prevailing parties in this matter, court costs should be taxed against
Defendants. A proposed Final Judgment is submitted herewith.
WHEREFORE, Plaintiffs, Hornbeck Offshore, L.L.C., the Chouest Entities and the
Bollinger Entities respectfully request that the Court enter the relief requested in this Motion for
Entry of Final Judgment and such other relief as the Court deems appropriate.

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.

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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 13th day of July, 2011.

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