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

Filing 29

MOTION for Leave to File Affidavits and Declaration 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 Hearing set for 7/28/2010 10:00 AM before Judge Martin L.C. Feldman. (Attachments: # 1 Exhibit, # 2 Affidavit, # 3 Affidavit, # 4 Affidavit, # 5 Affidavit, # 6 Affidavit, # 7 Affidavit, # 8 Affidavit, # 9 Affidavit, # 10 Memorandum in Support, # 11 Notice of Hearing, # 12 Proposed Order)(Rosenblum, Carl) (Additional attachment(s) added on 6/21/2010: # 13 Declaration of Ford Brett) (caa, ).

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

HORNBECK OFFSHORE SERVICES, L.L.C., Plaintiff VERSUS

* * *

CIVIL ACTION NO. 10-1663

SECTION F

* KENNETH LEE "KEN" SALAZAR, IN HIS OFFICIAL CAPACITY AS SECRETARY, UNITED STATES DEPARTMENT OF THE INTERIOR; UNITED STATES DEPARTMENT OF THE INTERIOR; ROBERT "BOB" ABBEY, IN HIS OFFICIAL CAPACITY AS ACTING DIRECTOR, MINERALS MANAGEMENT SERVICE; AND MINERALS MANAGEMENT SERVICE, Defendants * * * * * * * * * * * * * MAGISTRATE 2 JUDGE FELDMAN

AFFIDAVIT OF TODD M. HORNBECK STATE OF TEXAS COUNTY OF HARRIS Personally came and appeared before me, Todd M. Hornbeck, who being first duly sworn, deposed and said: 1. I am a person of the full age of majority and competent to execute this affidavit. I am the Chairman, Chief Executive Officer, and President of Hornbeck Offshore Services, Inc. and its subsidiaries including the Plaintiff in this proceeding ("Hornbeck") and have personal knowledge of the facts set forth herein. 2. Hornbeck owns and operates a fleet of 55 offshore supply vessels ("OSV's) and multi-purpose support vessels ("MPSV's), of which 49 are U.S. flagged and Jones Act qualified. These vessels perform services in connection with offshore oil and

{N2167551.2}