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

Filing 51

EXPARTE/CONSENT MOTION for Leave to File Declaration of Ford Brett 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. and Tampa Ship, L.L.C. (Attachments: # 1 Declaration of Ford Brett, # 2 Proposed Order)(Rosenblum, Carl) Modified on 6/21/2010 (caa, ).

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

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

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

SECTION F

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

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JUDGE FELDMAN

MAGISTRATE 2 MAGISTRATE WILKINSON

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PLAINTIFFS' EX-PARTE MOTION FOR LEAVE TO FILE DECLARATION OF FORD BRETT THAT WAS INADVERTENTLY NOT FILED WITH REC. DOC. 29 Pursuant to this Court's Orders dated June 11, 2010 and June 14, 2010,1 on June 16, 2010, Plaintiffs, Hornbeck Offshore Services, L.L.C. ("Hornbeck"), the Bollinger Entities and the Chouest Entities (collectively, "Plaintiffs"), filed a Motion to File Affidavits and Declaration in to the record. (Rec. Doc. 29). As indicated on the Index of Attachments (Rec. Doc. 29-1) filed
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(Rec. Docs. 10, 23).

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with the Motion, the Declaration of Ford Brett, one of the "peer review" experts, was to be attached. Plaintiffs have discovered that inadvertently the Declaration did not get filed.

Plaintiffs request leave of Court to file into the record the Declaration of Ford Brett, which is attached hereto, in order to correct the inadvertent omission and complete the record. WHEREFORE, the Plaintiffs respectfully request that their motion for leave be granted. A proposed order is attached. Respectfully submitted,

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ARL 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. Washington, D.C. 20004 Telephone: [phone] Attorneys for Plaintiffs, Hornbeck Offshore Services, L.L.C., The Bollinger Entities, and The Chouest Entities.

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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 19th day of June 2010.

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