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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MEMORANDUM OF LAW IN SUPPORT OF 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 submit this memorandum of law in support of their Motion for Emergency Hearing seeking emergency consideration by the Court of their Motion to Enforce Preliminary Injunction Order. For the reasons detailed in the memorandum accompanying the

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Motion to Enforce Preliminary Injunction Order, good cause exists for the Court to consider the relief requested by Plaintiffs on an emergency basis. Given the national significance of this matter, Secretary Salazar's sworn testimony before a Senate Committee today, recent statements to the media by the Department of the Interior, and the Court's scheduling considerations, it is imperative that Plaintiffs' Motion to Enforce Preliminary Injunction Order be heard at the earliest possible time. Secretary Salazar's statements constitute a de facto continuance of the Moratorium in direct violation of the Court's Preliminary Injunction Order dated June 22, 2010 (Rec Doc. 68). Thus, Plaintiffs' Motion to Enforce Preliminary Injunction Order should be considered by the Court on an emergency basis. For the reasons set forth above, Plaintiffs respectfully submit that their Motion to Enforce Preliminary Injunction Order should be set for emergency hearing at the earliest available time. 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

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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.

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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