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

Filing 70

EXPARTE/CONSENT MOTION to Expedite for Emergency Hearing 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 Memorandum in Support, # 2 Proposed Order)(Rosenblum, Carl) Modified on 6/23/2010 (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' MOTION FOR EMERGENCY HEARING NOW INTO COURT, through undersigned counsel, come Plaintiffs, Hornbeck Offshore Services, L.L.C. ("Hornbeck"), the Bollinger Entities and the Chouest Entities (collectively, "Plaintiffs"), which respectfully move this Court for an emergency hearing on their Motion to Enforce Preliminary Injunction Order. As discussed more fully in the accompanying memorandum in support, Plaintiffs submit that good cause exists for an emergency hearing given the national significance of this matter, Secretary Salazar's sworn testimony before a Senate

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Committee today, recent statements to the media by the Department of the Interior, and the Court's scheduling considerations. The statements of Secretary Salazar continue to enforce the Moratorium. Secretary Salazar's statements are in direct violation of the Court's Preliminary Injunction Order dated June 22, 2010 (Rec. Doc. 68), which immediately prohibited Defendants from enforcing the Moratorium. WHEREFORE, Plaintiffs respectfully request that the Court grant their Motion for Emergency Hearing on their Motion to Enforce Preliminary Injunction Order and that the hearing be set at the earliest available time. A proposed order is attached hereto. 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 23rd day of June 2010.

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