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

Filing 45

RESPONSE/MEMORANDUM in Opposition filed by Center for Biological Diversity, Defenders of Wildlife, Florida Wildlife Federation, Natural Resources Defense Council, Sierra Club re 7 MOTION for Preliminary Injunction. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11.1, # 12 Exhibit 11.2, # 13 Exhibit 12.1, # 14 Exhibit 12.2, # 15 Exhibit 13, # 16 Exhibit 14, # 17 Exhibit 15, # 18 Exhibit 16, # 19 Exhibit 17)(Suttles, John)

DECLARATION OF STEVE HOWARD, SUNBURST COMPANY 1. 1, Steve Howard, am over 18 years of age and have personal knowledge following facts. of the

2. I own and operate the Sunburst Company, a vacation rental home business located at 59 Canal Street, Seagrove Beach, Walton County, Florida. 3. Walton County is located on Northwest Florida's Gulf Coast and the BP Deepwater Horizon Oil Spill has directly and adversely affected it. 4. Similarly, the Sunburst Company has been adversely affected by the threat of oil on our beaches. The Sunburst Company manages over 70 homes with an annual gross revenue in excess of $4 million. S. The threat of oil has significantly chilled our business. Specifically, because ofthe BP Deepwater Horizon oil spill Sunburst has received over 32 cancellations with lost revenue of approximately $100,000.00. 6. Until the oil spill is controlled and assurances received that the clean up is effective and oil contained our business remains tentative at best. 7. As such it is premature to lift President Obarna's moratorium on oil drilling in the Gulf of Mexico until the cause of the failure can be determined and plans developed to establish safe guards to protect the gulf and the those states, like Florida, from future oil spills and blow-outs. 8. My livelihood relies on clean water and an oil free environment. I am directly affected by the oil spill, the moratorium, and the proposed and yet-to-bediscovered solutions that would prevent future catastrophic events in the Gulf of Mexico .. I DECLARE under penalty of perjury under the laws of the United States and the laws of the State of Florida that the foregoing is true and correct.

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Steve