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

Filing 277

RESPONSE/MEMORANDUM in Opposition filed by All Defendants re 276 MOTION Entry of Final Judgment. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B)(Piropato, Marissa)

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,
v.

MAGISTRATE 2
MAGISTRATE WILKINSON

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

DEFENDANTS’ LIMITED OPPOSITION TO
PLAINTIFFS’ MOTION FOR ENTRY OF FINAL JUDGMENT
Defendants, Kenneth Lee Salazar, the United States Department of the Interior, Michael
R. Bromwich, and the Bureau of Ocean Energy Management, Regulation, and Enforcement
(“Defendants”) hereby file this limited opposition to Plaintiffs’ Motion for Entry of Final
Judgment and accompanying Proposed Final Judgment. Dkt. #276. Defense counsel has
conferred with Plaintiffs’ counsel, who indicated that at this juncture Plaintiffs do not consent to
the relief sought herein, but should Plaintiffs’ views change, they would notify the Court.

Defendants request that this Court enter final judgment in accordance with its previous
orders in which the Court’s finding of contempt was limited in time to conduct occurring from
June 22, 2010 to September 29, 2010. Dkts. #226 & #265.
Defendants thus respectfully request that this Court enter Final Judgment so that this
Court’s finding of civil contempt is in the past tense as set forth in Defendants’ proposed Final
Judgment. See Ex. A.

Respectfully submitted, August 1, 2011

IGNACIA S. MORENO
Assistant Attorney General
U.S. Dept. of Justice, Env’t & Nat. Resources Div.
/s/Marissa A. Piropato
GUILLERMO A. MONTERO (T.A.)
BRIAN COLLINS
KRISTOFOR R. SWANSON
MARISSA A. 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]

DEFENDANTS’ LIMITED OPP’N TO MOTION FOR ENTRY OF FINAL JUDGMENT

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CERTIFICATE OF SERVICE
I hereby certify that on August 1, 2011, I caused a copy of the foregoing to be served
through the Court’s CM/ECF System to all parties.

/s/ Marissa A. Piropato
Marissa A. Piropato

DEFENDANTS’ LIMITED OPP’N TO MOTION FOR ENTRY OF FINAL JUDGMENT

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