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

Filing 94

EXPARTE/CONSENT MOTION to Substitute Party. Party Bureau of Ocean Energy Management, Regulation, and Enforcement; Michael Bromwich, in his official capacity as director, Bureau of Ocean Energy Management, Regulation, and Enforcement to be substituted in place of Minerals Management Service; Robert Bob Abbey, in his official capacity as acting director, Minerals Management Service 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.. (Attachments: # 1 Memorandum in Support, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Rosenblum, Carl)

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 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 * *

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JUDGE FELDMAN

MAGISTRATE 2 MAGISTRATE WILKINSON

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PLAINTIFFS' EX PARTE CONSENT MOTION TO SUBSTITUTE PARTIES NOW INTO COURT, through undersigned counsel, come Plaintiffs Hornbeck Offshore Services, L.L.C, the Bollinger Entities, and the Chouest Entities (collectively "Plaintiffs"), which respectfully move the Court for leave to substitute as defendants herein Bureau of Ocean Energy Management, Regulation, and Enforcement, for current defendant, Minerals Management Service, and Michael Bromwich, in his official capacity as director, Bureau of Ocean Energy Management, Regulation, and Enforcement, for current defendant, Robert "Bob" Abbey, in his

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official capacity as acting director, Minerals Management Service. Undersigned counsel has requested and obtained Defendants' consent to Plaintiffs' Ex Parte Consent Motion. For the reasons set forth in the memorandum in support filed herewith, Plaintiffs' Ex Parte Consent Motion should be granted. WHEREFORE, Plaintiffs, hereby move the Court for an Order granting their Ex Parte Consent Motion and substituting as defendants herein Bureau of Ocean Energy Management, Regulation, and Enforcement, for current defendant, Minerals Management Service, and Michael Bromwich, in his official capacity as director, Bureau of Ocean Energy Management, Regulation, and Enforcement, for current defendant, Robert "Bob" Abbey, in his official capacity as acting director, Minerals Management Service. 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.,

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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 28th day of June, 2010.

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