This document is a complaint filed by the State of Florida against BP Exploration & Production Inc., BP p.l.c., BP America Production Company, and Halliburton Energy Services, Inc. regarding economic damages suffered by Florida from the 2010 Deepwater Horizon oil spill in the Gulf of Mexico. The complaint alleges that BP and Halliburton's negligent actions led to the uncontrolled oil spill, which damaged Florida's tourism-dependent economy. It asserts jurisdiction and provides background on the parties involved. The complaint describes the events leading up to the spill and allegations of negligence against the defendants regarding well design, cementing, and blowout preventer failures. Florida seeks damages for lost tax revenue and economic losses due to impacts on tourism
The defendants filed a motion to dismiss the indictment charging them with violating export control laws. They argue that the language of the US Munitions List regulating the export of military equipment is unconstitutionally vague and does not provide fair notice of what requires an export license. Specifically, the list does not enumerate the exact parts the defendants were charged with exporting. This violates the due process requirement that criminal statutes define the prohibited conduct clearly. The defendants therefore could not have known their actions were illegal.
- JetBlue operated the first scheduled flight between the US and Cuba on August 31st, connecting Ft. Lauderdale and Santa Clara. American Airlines and Silver Airways also began non-Havana flights from Ft. Lauderdale on September 1st and 7th respectively.
- The DOT finalized its allocation of 20 daily flight frequencies between the US and Havana on August 31st, awarding routes to 10 US carriers including American, Delta, United, JetBlue and Southwest.
- Scheduled flights are expected to replace charter flights as the main form of air travel between the US and Cuba, offering lower prices, more destinations and connecting flights. Over 30 daily round-trip flights are
This document provides testimony opposing resolutions (HR 113, HCR 153, SR 45, SR 93) that would exempt Hawaii from the U.S. build requirement of the Jones Act for large ocean-going ships. It provides background on the Jones Act and examines a GAO report on the potential effects of exempting Puerto Rico from the Jones Act. While reform should be considered, a full exemption is not in Hawaii's best interest due to national security, homeland security, and support for the domestic shipping and maritime industries.
This document is an amicus brief in support of Mingo Logan Coal Company's motion for summary judgment against the EPA. It argues that EPA's use of its Clean Water Act Section 404(c) authority to modify a Section 404 permit already issued by the Army Corps of Engineers sets an unprecedented and disruptive precedent. It asserts that this action by EPA introduces tremendous uncertainty for all current and future Section 404 permit holders, increasing costs and risks and deterring important economic investment and development that requires Section 404 permits. The amicus brief represents a broad coalition of industry groups dependent on Section 404 permitting, and contends EPA's action threatens substantial negative economic impacts.
This document is an amicus curiae memorandum submitted in a lawsuit regarding the Honolulu High-Capacity Transit Corridor Project. It argues that the defendants violated Section 4(f) of the Department of Transportation Act in two ways: 1) they failed to fully identify all historic resources before approving the project, so they cannot substantiate that no additional resources will be used; and 2) they ignored indirect effects on resources that constitute constructive use, failing to avoid and minimize harm as required. The memorandum asserts that the court should grant the plaintiffs' motion for summary judgment and order compliance with Section 4(f).
FindLaw | Document Destruction Charges Against Stanford EmployeeLegalDocs
Bruce Perraud, a security specialist for Stanford Financial Group, is charged with destroying records related to an ongoing SEC investigation into Stanford. The SEC had filed a complaint against Stanford alleging a fraudulent investment scheme and obtained a court order appointing a receiver and prohibiting the destruction of any Stanford records. After learning of the SEC investigation and court order, Perraud arranged for a commercial shredding company to destroy bins full of Stanford documents at the Fort Lauderdale office while he supervised.
This document is the Federal Defendants' Answer to the Plaintiffs' Complaint filed in the United States District Court for the District of Hawaii. The Federal Defendants deny many of the allegations in the Plaintiffs' Complaint and provide responses to each paragraph corresponding to the Complaint. The Federal Defendants also assert that matters not specifically admitted in their Answer are hereby denied.
The defendants filed a motion to dismiss the indictment charging them with violating export control laws. They argue that the language of the US Munitions List regulating the export of military equipment is unconstitutionally vague and does not provide fair notice of what requires an export license. Specifically, the list does not enumerate the exact parts the defendants were charged with exporting. This violates the due process requirement that criminal statutes define the prohibited conduct clearly. The defendants therefore could not have known their actions were illegal.
- JetBlue operated the first scheduled flight between the US and Cuba on August 31st, connecting Ft. Lauderdale and Santa Clara. American Airlines and Silver Airways also began non-Havana flights from Ft. Lauderdale on September 1st and 7th respectively.
- The DOT finalized its allocation of 20 daily flight frequencies between the US and Havana on August 31st, awarding routes to 10 US carriers including American, Delta, United, JetBlue and Southwest.
- Scheduled flights are expected to replace charter flights as the main form of air travel between the US and Cuba, offering lower prices, more destinations and connecting flights. Over 30 daily round-trip flights are
This document provides testimony opposing resolutions (HR 113, HCR 153, SR 45, SR 93) that would exempt Hawaii from the U.S. build requirement of the Jones Act for large ocean-going ships. It provides background on the Jones Act and examines a GAO report on the potential effects of exempting Puerto Rico from the Jones Act. While reform should be considered, a full exemption is not in Hawaii's best interest due to national security, homeland security, and support for the domestic shipping and maritime industries.
This document is an amicus brief in support of Mingo Logan Coal Company's motion for summary judgment against the EPA. It argues that EPA's use of its Clean Water Act Section 404(c) authority to modify a Section 404 permit already issued by the Army Corps of Engineers sets an unprecedented and disruptive precedent. It asserts that this action by EPA introduces tremendous uncertainty for all current and future Section 404 permit holders, increasing costs and risks and deterring important economic investment and development that requires Section 404 permits. The amicus brief represents a broad coalition of industry groups dependent on Section 404 permitting, and contends EPA's action threatens substantial negative economic impacts.
This document is an amicus curiae memorandum submitted in a lawsuit regarding the Honolulu High-Capacity Transit Corridor Project. It argues that the defendants violated Section 4(f) of the Department of Transportation Act in two ways: 1) they failed to fully identify all historic resources before approving the project, so they cannot substantiate that no additional resources will be used; and 2) they ignored indirect effects on resources that constitute constructive use, failing to avoid and minimize harm as required. The memorandum asserts that the court should grant the plaintiffs' motion for summary judgment and order compliance with Section 4(f).
FindLaw | Document Destruction Charges Against Stanford EmployeeLegalDocs
Bruce Perraud, a security specialist for Stanford Financial Group, is charged with destroying records related to an ongoing SEC investigation into Stanford. The SEC had filed a complaint against Stanford alleging a fraudulent investment scheme and obtained a court order appointing a receiver and prohibiting the destruction of any Stanford records. After learning of the SEC investigation and court order, Perraud arranged for a commercial shredding company to destroy bins full of Stanford documents at the Fort Lauderdale office while he supervised.
This document is the Federal Defendants' Answer to the Plaintiffs' Complaint filed in the United States District Court for the District of Hawaii. The Federal Defendants deny many of the allegations in the Plaintiffs' Complaint and provide responses to each paragraph corresponding to the Complaint. The Federal Defendants also assert that matters not specifically admitted in their Answer are hereby denied.
This document is the Federal Defendants' Answer to the Plaintiffs' Complaint filed in the United States District Court for the District of Hawaii. The Federal Defendants deny many of the allegations in the Plaintiffs' Complaint and provide responses to each numbered paragraph corresponding to the Complaint. The Federal Defendants also assert that matters not specifically admitted in their Answer are denied.
The document summarizes a resolution that approves a covenant establishing the Commonwealth of the Northern Mariana Islands in political union with the United States of America. It gives the Northern Mariana Islands internal self-government and U.S. citizenship while allowing the U.S. to fulfill its security and defense responsibilities in the region. The covenant was approved by the U.S., Northern Mariana Islands legislature, and people of the Northern Mariana Islands.
The French Gourmet Inc., indicted recently for knowingly making false attestations on I-9 Forms, hiring employees unauthorized to work in the U.S., and employing those aliens after learning of their ineligibility to work. U.S. v. The French Gourmet Inc.
A Brief presentation on the Code of Federal Regulations in Pharmaceuticals (21 CFR), which covers the following aspects:
- Introduction to CFR
- Organization and structure of CFR
- History of CFR
- Table of Contents
- Title 21; CFR in Pharmaceuticals
- IND Application process regulations
- Research tools in CFR
This document is a reply brief filed by defendants in response to a lawsuit brought by a former inmate, Traian Bujduveanu, against his residential reentry center Dismas Charities and three employees. The defendants argue that Bujduveanu violated terms of his release from federal prison by driving without permission and possessing a cell phone. As a result, the Federal Bureau of Prisons, not the defendants, transferred Bujduveanu back to prison to complete his sentence. The defendants provide 27 undisputed facts with supporting documentation showing Bujduveanu signed forms acknowledging he would abide by rules prohibiting unauthorized driving and cell phone possession. The defendants argue they were not legally responsible for Bu
The Code of Federal Regulations is the codification of rules and regulations issued by federal agencies in the United States. It is divided into 50 titles that are further divided into chapters and parts covering broad subject areas. New regulations are added daily and published in the Federal Register before being codified in the CFR. The CFR titles cover all areas of federal regulation including transportation, labor, agriculture, healthcare and more.
Civil litigation seeks replacement of some 300 residential housing units that the for-profit university unlawfully displaced in its real estate buying spree
This order rules on the defendants' request for judicial notice in a case about the Honolulu High-Capacity Transit Corridor Project. The court grants the request to take judicial notice of exhibits A, B, and C, which are the Draft Environmental Impact Statement, Final Environmental Impact Statement, and Record of Decision, as they are incorporated into the complaint by reference. The court also grants the request to take judicial notice of the existence of other exhibits consisting of public records, but does not take judicial notice of the defendants' descriptions of those exhibits.
The Code of Federal Regulations (CFR) is the codification of rules and regulations issued by federal agencies in the United States. It is divided into 50 titles that represent broad subject areas subject to federal regulation. The CFR is updated through rules published in the Federal Register and issued as soft-cover volumes on a quarterly basis. It is also available online through the Electronic CFR, which is updated more frequently. Title 21 of the CFR covers regulations related to food and drugs, including current good manufacturing practice regulations for pharmaceuticals.
This document summarizes a court order on a motion to amend a complaint and a motion to intervene in a lawsuit challenging the approval of the Honolulu High-Capacity Transit Corridor Project. The court granted both motions. Regarding the motion to amend, the court found that while the statute of limitations had passed, the proposed additions to the complaint arose from the same facts and occurrences as the original complaint. Regarding the motion to intervene, the court allowed three organizations and an individual to intervene as defendants to represent interests not addressed by the existing defendants.
Pier & Berthing Facilities for Re-Development Russia, Volga River Delta, Cas...Igor Pisckounov
The document summarizes the sale of assets including a pier, berthing facilities, and land plot totaling 1.6 hectares located on the Volga River Delta in Russia. The assets were previously used for fish processing but are being offered for redevelopment into options like renewed fishing and processing, aquaculture, eco-tourism, logistics, or other uses. Interested parties are invited to submit proposals to acquire 100% ownership of the assets and can contact the listed financial advisor for more information.
Sixth Circuit Court of Appeals Decision in Harper v Muskingum Watershed Conse...Marcellus Drilling News
Anti-drilling landowners (backed by Food & Water Watch) claimed the Muskingum Watershed Conservancy District had violated the deed to the land it owns by leasing that land for Utica Shale drilling. The Sixth Circuit dismissed the case. The anti-drillers lost.
The document is a monograph analyzing the Joint Special Operations Task Force- Philippines (JSOTF-P) approach to conducting irregular warfare in the Philippines. The monograph examines how the JSOTF-P employs an indirect approach of working by, with, and through legitimate Filipino security forces while maintaining a small American military footprint. The monograph analyzes if this approach offers a suitable model for future U.S. military operations against terrorist networks in support of the Long War.
The plaintiff Southeastern Pennsylvania Transportation Authority (SEPTA) filed a class action lawsuit against The Bank of New York Mellon Corporation (BNY Mellon) on behalf of itself and other similarly situated clients of BNY Mellon. The lawsuit alleges that from at least 2000, BNY Mellon manipulated foreign currency exchange transactions to maximize profits for itself by charging inflated exchange rates when clients bought foreign currency and deflated rates when clients sold foreign currency. The lawsuit seeks to recover unlawful profits obtained through these practices and obtain injunctive relief. Jurisdiction and venue are proper as BNY Mellon is headquartered in New York.
OIL SPILL CLASSA CTION Safety supp complaint for tro R.K.
This document is a verified supplemental complaint filed against BP in the United States District Court for the Eastern District of Louisiana. It summarizes that fishermen have volunteered to assist BP in cleanup efforts of the Deepwater Horizon oil spill, but the master vessel charter agreement (MVCA) between BP and the fishermen fails to address BP's responsibilities for ensuring safety regarding hazardous chemical exposure. The complaint requests the court order BP to acknowledge and fulfill its duties to provide adequate safety oversight, training, monitoring, and personal protective equipment for fishermen working under the MVCA.
Citation Information Griggs, J. W. (2011). BP GULF OF MEXICO O.docxmonicafrancis71118
Citation Information:
Griggs, J. W. (2011). BP GULF OF MEXICO OIL SPILL. Energy Law Journal, 32(1), 57-79. Retrieved from http://search.proquest.com/docview/869071045?accountid=45844
Synopsis: The blowout of BP's Macondo well in the Gulf of Mexico on April 20, 2010, provided the first major test of the national oil spill containment and response apparatus put in place by the Oil Pollution Act of 1990. News media coverage of the blowout displayed a lack of awareness of the Act or the mechanisms it had put in place to respond to major oil spills. Many questions raised by the media are answered or explained by the statute and its regulations. This article discusses the Act's provisions as they relate to the Macondo blowout, its effectiveness in dealing with the spill, and the prospects for amending the law.
I. THE MACONDO BLOWOUT
The blowout of British Petroleum?s (BP) Macondo well in the deep water of the Gulf of Mexico was the largest accidental oil spill in the world, greater than both the Ixtoc blowout off the coast of Mexico and the Exxon Valdez spill in Alaska.1 Eleven crew members of the Deepwater Horizon drilling rig were killed, others were injured, the livelihoods of thousands of fishermen were impacted, countless marine animals and organisms were destroyed, and marshes and beaches in Louisiana, Mississippi, Alabama, and Florida were fouled. The blowout dominated news coverage from April 20, 2010, until the blowout was finally capped on July 15, 2010. Hundreds of lawsuits have been filed.2 There have been hearings before a joint investigatory panel of the Coast Guard and the Department of the Interior,3 an investigation by a commission appointed by President Obama,4 and extensive Congressional hearings.5
In the aftermath of the spill, resource damage assessment has begun, but will take time to complete. Some 185,000,000 gallons (4.4 million barrels) of oil were discharged,6 and, while clean-up efforts and natural processes appear to have removed much of the oil from the water surface, the effects on the Gulf of Mexico may last for decades. Media attention, once intense, is now focused elsewhere.7 The intensive media coverage raised many questions that were left unanswered before the media moved on to other issues. Among these are questions regarding who was in charge, delayed emergency response efforts, the laxity of federal oversight, the culpability of the companies involved,8 the impact of the oil on the ecosystem, the use of dispersants, and the ability of the environment to recover. Resolving the larger questions concerning resource damage will take years and involve disciplines outside the law. It is not the purpose of this article to resolve these issues or assess blame for the spill. Rather, the purpose of this article is more modest and limited: to address those questions that relate to the adequacy and effectiveness of the existing legal regime for responding to offshore oil spills.
II. THE OIL POLLUTION ACT OF 1990
.
BP Oil Spill and if the BP Oil Spill had happened in India and Comparative study between India and States with respect to Oil SpillBP Oil Spill .What if the BP Oil Spill had happened in India and Comparative study between India and States with respect to Oil Spill.
The document provides details about the 2010 BP oil spill in the Gulf of Mexico. It describes:
- The spill was the largest accidental spill, releasing millions of barrels of oil over months and killing wildlife and affecting livelihoods.
- Investigations found BP and its partners were negligent by underestimating the spill size and having inadequate response plans.
- BP faced billions in fines and penalties under the Clean Water Act and Oil Pollution Act for environmental damages.
- The case highlighted deficiencies in regulations and response capabilities for oil spills, especially large deepwater spills.
Gao- Offshore Oil & gas resources decommissioning liabilitiesDr Dev Kambhampati
The GAO report examines the Department of the Interior's (Interior) management of decommissioning liabilities from offshore oil and gas production in the Gulf of Mexico. It finds that Interior has procedures to oversee decommissioning and estimate costs, but its data system for cost estimates is inaccurate. Interior's procedures for obtaining financial assurances from companies pose risks to the federal government if companies do not fulfill decommissioning obligations. Interior faces challenges in obtaining accurate cost information from companies and managing potential decommissioning liabilities of billions of dollars if companies default.
This document discusses potential legal liability arising from the 2010 Deepwater Horizon oil spill in the Gulf of Mexico. It outlines various environmental laws that could apply including the Oil Pollution Act, Clean Water Act, Endangered Species Act, and others. It examines which parties may be considered responsible under these statutes, such as BP as operator, Transocean as rig owner, and Halliburton as contractor. The document also reviews elements of liability, available damages, and penalties under these laws, which could total in the billions of dollars depending on whether gross negligence or willful misconduct is found.
At last the discussion of Puerto Rico’s economic and debt crises will consider the biggest restrictions that limit Puerto Rico’s authority to make the structural changes it needs: laws and regulations enacted for a bigger, more developed economy.
This document is the Federal Defendants' Answer to the Plaintiffs' Complaint filed in the United States District Court for the District of Hawaii. The Federal Defendants deny many of the allegations in the Plaintiffs' Complaint and provide responses to each numbered paragraph corresponding to the Complaint. The Federal Defendants also assert that matters not specifically admitted in their Answer are denied.
The document summarizes a resolution that approves a covenant establishing the Commonwealth of the Northern Mariana Islands in political union with the United States of America. It gives the Northern Mariana Islands internal self-government and U.S. citizenship while allowing the U.S. to fulfill its security and defense responsibilities in the region. The covenant was approved by the U.S., Northern Mariana Islands legislature, and people of the Northern Mariana Islands.
The French Gourmet Inc., indicted recently for knowingly making false attestations on I-9 Forms, hiring employees unauthorized to work in the U.S., and employing those aliens after learning of their ineligibility to work. U.S. v. The French Gourmet Inc.
A Brief presentation on the Code of Federal Regulations in Pharmaceuticals (21 CFR), which covers the following aspects:
- Introduction to CFR
- Organization and structure of CFR
- History of CFR
- Table of Contents
- Title 21; CFR in Pharmaceuticals
- IND Application process regulations
- Research tools in CFR
This document is a reply brief filed by defendants in response to a lawsuit brought by a former inmate, Traian Bujduveanu, against his residential reentry center Dismas Charities and three employees. The defendants argue that Bujduveanu violated terms of his release from federal prison by driving without permission and possessing a cell phone. As a result, the Federal Bureau of Prisons, not the defendants, transferred Bujduveanu back to prison to complete his sentence. The defendants provide 27 undisputed facts with supporting documentation showing Bujduveanu signed forms acknowledging he would abide by rules prohibiting unauthorized driving and cell phone possession. The defendants argue they were not legally responsible for Bu
The Code of Federal Regulations is the codification of rules and regulations issued by federal agencies in the United States. It is divided into 50 titles that are further divided into chapters and parts covering broad subject areas. New regulations are added daily and published in the Federal Register before being codified in the CFR. The CFR titles cover all areas of federal regulation including transportation, labor, agriculture, healthcare and more.
Civil litigation seeks replacement of some 300 residential housing units that the for-profit university unlawfully displaced in its real estate buying spree
This order rules on the defendants' request for judicial notice in a case about the Honolulu High-Capacity Transit Corridor Project. The court grants the request to take judicial notice of exhibits A, B, and C, which are the Draft Environmental Impact Statement, Final Environmental Impact Statement, and Record of Decision, as they are incorporated into the complaint by reference. The court also grants the request to take judicial notice of the existence of other exhibits consisting of public records, but does not take judicial notice of the defendants' descriptions of those exhibits.
The Code of Federal Regulations (CFR) is the codification of rules and regulations issued by federal agencies in the United States. It is divided into 50 titles that represent broad subject areas subject to federal regulation. The CFR is updated through rules published in the Federal Register and issued as soft-cover volumes on a quarterly basis. It is also available online through the Electronic CFR, which is updated more frequently. Title 21 of the CFR covers regulations related to food and drugs, including current good manufacturing practice regulations for pharmaceuticals.
This document summarizes a court order on a motion to amend a complaint and a motion to intervene in a lawsuit challenging the approval of the Honolulu High-Capacity Transit Corridor Project. The court granted both motions. Regarding the motion to amend, the court found that while the statute of limitations had passed, the proposed additions to the complaint arose from the same facts and occurrences as the original complaint. Regarding the motion to intervene, the court allowed three organizations and an individual to intervene as defendants to represent interests not addressed by the existing defendants.
Pier & Berthing Facilities for Re-Development Russia, Volga River Delta, Cas...Igor Pisckounov
The document summarizes the sale of assets including a pier, berthing facilities, and land plot totaling 1.6 hectares located on the Volga River Delta in Russia. The assets were previously used for fish processing but are being offered for redevelopment into options like renewed fishing and processing, aquaculture, eco-tourism, logistics, or other uses. Interested parties are invited to submit proposals to acquire 100% ownership of the assets and can contact the listed financial advisor for more information.
Sixth Circuit Court of Appeals Decision in Harper v Muskingum Watershed Conse...Marcellus Drilling News
Anti-drilling landowners (backed by Food & Water Watch) claimed the Muskingum Watershed Conservancy District had violated the deed to the land it owns by leasing that land for Utica Shale drilling. The Sixth Circuit dismissed the case. The anti-drillers lost.
The document is a monograph analyzing the Joint Special Operations Task Force- Philippines (JSOTF-P) approach to conducting irregular warfare in the Philippines. The monograph examines how the JSOTF-P employs an indirect approach of working by, with, and through legitimate Filipino security forces while maintaining a small American military footprint. The monograph analyzes if this approach offers a suitable model for future U.S. military operations against terrorist networks in support of the Long War.
The plaintiff Southeastern Pennsylvania Transportation Authority (SEPTA) filed a class action lawsuit against The Bank of New York Mellon Corporation (BNY Mellon) on behalf of itself and other similarly situated clients of BNY Mellon. The lawsuit alleges that from at least 2000, BNY Mellon manipulated foreign currency exchange transactions to maximize profits for itself by charging inflated exchange rates when clients bought foreign currency and deflated rates when clients sold foreign currency. The lawsuit seeks to recover unlawful profits obtained through these practices and obtain injunctive relief. Jurisdiction and venue are proper as BNY Mellon is headquartered in New York.
OIL SPILL CLASSA CTION Safety supp complaint for tro R.K.
This document is a verified supplemental complaint filed against BP in the United States District Court for the Eastern District of Louisiana. It summarizes that fishermen have volunteered to assist BP in cleanup efforts of the Deepwater Horizon oil spill, but the master vessel charter agreement (MVCA) between BP and the fishermen fails to address BP's responsibilities for ensuring safety regarding hazardous chemical exposure. The complaint requests the court order BP to acknowledge and fulfill its duties to provide adequate safety oversight, training, monitoring, and personal protective equipment for fishermen working under the MVCA.
Citation Information Griggs, J. W. (2011). BP GULF OF MEXICO O.docxmonicafrancis71118
Citation Information:
Griggs, J. W. (2011). BP GULF OF MEXICO OIL SPILL. Energy Law Journal, 32(1), 57-79. Retrieved from http://search.proquest.com/docview/869071045?accountid=45844
Synopsis: The blowout of BP's Macondo well in the Gulf of Mexico on April 20, 2010, provided the first major test of the national oil spill containment and response apparatus put in place by the Oil Pollution Act of 1990. News media coverage of the blowout displayed a lack of awareness of the Act or the mechanisms it had put in place to respond to major oil spills. Many questions raised by the media are answered or explained by the statute and its regulations. This article discusses the Act's provisions as they relate to the Macondo blowout, its effectiveness in dealing with the spill, and the prospects for amending the law.
I. THE MACONDO BLOWOUT
The blowout of British Petroleum?s (BP) Macondo well in the deep water of the Gulf of Mexico was the largest accidental oil spill in the world, greater than both the Ixtoc blowout off the coast of Mexico and the Exxon Valdez spill in Alaska.1 Eleven crew members of the Deepwater Horizon drilling rig were killed, others were injured, the livelihoods of thousands of fishermen were impacted, countless marine animals and organisms were destroyed, and marshes and beaches in Louisiana, Mississippi, Alabama, and Florida were fouled. The blowout dominated news coverage from April 20, 2010, until the blowout was finally capped on July 15, 2010. Hundreds of lawsuits have been filed.2 There have been hearings before a joint investigatory panel of the Coast Guard and the Department of the Interior,3 an investigation by a commission appointed by President Obama,4 and extensive Congressional hearings.5
In the aftermath of the spill, resource damage assessment has begun, but will take time to complete. Some 185,000,000 gallons (4.4 million barrels) of oil were discharged,6 and, while clean-up efforts and natural processes appear to have removed much of the oil from the water surface, the effects on the Gulf of Mexico may last for decades. Media attention, once intense, is now focused elsewhere.7 The intensive media coverage raised many questions that were left unanswered before the media moved on to other issues. Among these are questions regarding who was in charge, delayed emergency response efforts, the laxity of federal oversight, the culpability of the companies involved,8 the impact of the oil on the ecosystem, the use of dispersants, and the ability of the environment to recover. Resolving the larger questions concerning resource damage will take years and involve disciplines outside the law. It is not the purpose of this article to resolve these issues or assess blame for the spill. Rather, the purpose of this article is more modest and limited: to address those questions that relate to the adequacy and effectiveness of the existing legal regime for responding to offshore oil spills.
II. THE OIL POLLUTION ACT OF 1990
.
BP Oil Spill and if the BP Oil Spill had happened in India and Comparative study between India and States with respect to Oil SpillBP Oil Spill .What if the BP Oil Spill had happened in India and Comparative study between India and States with respect to Oil Spill.
The document provides details about the 2010 BP oil spill in the Gulf of Mexico. It describes:
- The spill was the largest accidental spill, releasing millions of barrels of oil over months and killing wildlife and affecting livelihoods.
- Investigations found BP and its partners were negligent by underestimating the spill size and having inadequate response plans.
- BP faced billions in fines and penalties under the Clean Water Act and Oil Pollution Act for environmental damages.
- The case highlighted deficiencies in regulations and response capabilities for oil spills, especially large deepwater spills.
Gao- Offshore Oil & gas resources decommissioning liabilitiesDr Dev Kambhampati
The GAO report examines the Department of the Interior's (Interior) management of decommissioning liabilities from offshore oil and gas production in the Gulf of Mexico. It finds that Interior has procedures to oversee decommissioning and estimate costs, but its data system for cost estimates is inaccurate. Interior's procedures for obtaining financial assurances from companies pose risks to the federal government if companies do not fulfill decommissioning obligations. Interior faces challenges in obtaining accurate cost information from companies and managing potential decommissioning liabilities of billions of dollars if companies default.
This document discusses potential legal liability arising from the 2010 Deepwater Horizon oil spill in the Gulf of Mexico. It outlines various environmental laws that could apply including the Oil Pollution Act, Clean Water Act, Endangered Species Act, and others. It examines which parties may be considered responsible under these statutes, such as BP as operator, Transocean as rig owner, and Halliburton as contractor. The document also reviews elements of liability, available damages, and penalties under these laws, which could total in the billions of dollars depending on whether gross negligence or willful misconduct is found.
At last the discussion of Puerto Rico’s economic and debt crises will consider the biggest restrictions that limit Puerto Rico’s authority to make the structural changes it needs: laws and regulations enacted for a bigger, more developed economy.
ACI’s National Forum on Admiralty & Maritime Claims and Litigation has been tailored to provide corporate counsel, claims counsel, and private practice defense attorneys with the expert knowledge and key strategies that they need to successfully defend against maritime litigation.
Complaint filed today 5/6/10: United Comerical Fishermans Association v. BP and Others
VERIFIED SUPPLEMENTAL COMPLAINT FOR DECLARATORY JUDGMENT AND INJUNCTIVE RELIEF
1. Plaintiff appearing herein is George Barisich, individually and on behalf of the United Commercial Fisherman’s Association, Inc. as President thereof. Mr. Barisich is a natural person of the full age of majority domiciled in, and a citizen of, the State of Louisiana, Parish of St. Bernard. Plaintiff has been presented with a Master Vessel Charter Agreement (“MVCA”) drafted by BP, a copy of which is attached and incorporated as Ex. A. Members of the United Commercial Fisherman’s Association have entered into MVCAs with BP and have completed some training as required by BP.
This document summarizes a Supreme Court of the Philippines case regarding the constitutionality of Republic Act No. 9522, which adjusted the country's archipelagic baselines and classified the baseline regime of nearby territories. Petitioners argued that RA 9522 reduced Philippine maritime territory and opened internal waters to foreign passage, violating the constitution. Respondents defended RA 9522 as complying with the UN Convention on the Law of the Sea to delineate maritime zones. The Court found that RA 9522 was a statutory tool for delimiting maritime zones under UNCLOS, not territory, and that classifying nearby areas as "regimes of islands" did not weaken sovereignty claims over those areas.
The document discusses the Nairobi Wreck Removal Convention and its impact on shipping operations and liability. It summarizes that the convention aims to clarify responsibilities and require insurance for wreck removal, addressing gaps in previous laws. It analyzes key aspects of the convention including expanded definitions of hazards and interests, mandatory insurance for ships over 300 tons, and placing liability on registered owners. The convention establishes uniform international standards for prompt wreck removal in areas beyond territorial waters.
This document outlines a proposed class action settlement agreement between BP and plaintiffs regarding economic losses from the 2010 Deepwater Horizon oil spill. It defines the Economic and Property Damages Settlement Class eligible to make claims. The class includes individuals and businesses in Gulf Coast areas and waters affected by the spill. It establishes several categories for compensation, including programs for seafood industry losses, economic damages, subsistence losses, and damages to coastal real property and wetlands. The agreement is subject to court approval and allows class members who sign a release to receive prompt payment prior to final approval.
Respone each with 110 Response 1According to Investopedia .docxwilfredoa1
Respone each with 110
Response 1:
According to Investopedia it defines the Jones Act as a legislation that regulates maritime commerce between U.S. cities. The Jones Act is found in Section 27 of the Merchant Marine Act of 1920. The act required that goods and passengers transported by water between U.S. ports be done in U.S.-made ships, owned by U.S. citizens and crewed by U.S. citizens. The Jones Act also provided sailors with additional rights, including the ability to seek damages from the crew, captain or ship owner in the case of injury.
“Some provisions of the Jones Act are considered to be protectionist in nature as it requires ships to be U.S.-flagged, crewed and owned. This may price ship builders and operating companies out of the international market because the added expense and higher labor costs make companies less competitive. Today, at least 75% of a ship's crew must be comprised of U.S. citizens.”
I am totally against the Jones Act because it limits many job opportunities and not allowed legal immigrants with maritime experiences to do business domestically. There are several legal immigrants that are highly skilled and know how to navigate the open seas. Therefore, the Jones Act would be more diversify and beneficial if allowed legal immigrants to bring their ideas to the table. For me I think if you are qualified and your ship passed a safety inspection whether it was U.S. made ship or not it should be able to navigate between ports. The more diversify a business is the better it will grow due to the fact that everybody brings different ideas to the table. In my opinion I think they should get rid of the Jones Act and I think the Jones Act is obsolete.
Jones Act is a maritime law that was enacted in the 1920s to address Seamen’s industrial injury dispute with vessel owners with a no fault determination before service and a minimum of 31 months wait period for benefit. It also addressed the issue of ship flagging and domestic commerce with the United States territorial waters. The Jones act defines a seaman as an employee of a sea vessel that spends a minimum of seventy (70%) of their time working on a vessel at sea
keeping the MTS (
maritime transportation system) functioning smoothly in the support of commerce, developing security capabilities, shipment loading/unloading to provide efficiency benefits (TRANSPORTATION RESEARCH BOARD, 2004).
The Act as a g
eneral maritime law provided seamen a no-fault short-term benefits that was less extensive than those provided by industrial insurance for disabled employees. The Jones Act and general maritime law gave seamen the right to sue for damages – a right that is not extended to employees under industrial insurance or workers compensation insurance. The Jones Act does not cover Long-term disability, pensions, vocational training, and survivor benefits for the seamen. It is interesting to know that there is no payroll deduction under the Jones Act. Presumably, the seam.
This document summarizes information from an EPA investigation into the smuggling of ozone depleting substances. It discusses EPA's criminal investigation division and efforts to enforce regulations on ODS under the Clean Air Act and Montreal Protocol. The document outlines a case called Operation Catch-22 that targeted an international criminal network involved in smuggling the ODS HCFC-22. It provides details on the criminal cases brought against importers, distributors, and others involved in the smuggling operation.
Два иска США против Коломойского и Боголюбова конкретно касаются двух зданий, которые были куплены на деньги, выведенные из ПриватБанка — офисное здание CompuCom Campus в Даллесе и PNC Plaza Луисвилле. Общая стоимость зданий составляет около $70 млн.
This document is a verified petition filed in a US bankruptcy court seeking recognition of a foreign bankruptcy proceeding of Compania Mexicana de Aviacion (Mexicana) that was commenced in Mexico. Mexicana operates Mexicana Airlines, Mexico's largest airline. The petition seeks recognition of Maru E. Johansen as the foreign representative of Mexicana and recognition of the Mexican bankruptcy proceeding as a foreign main proceeding. Mexicana is seeking Chapter 15 bankruptcy protections in the US to protect its US assets during its restructuring in Mexico.
This document is a superseding indictment charging multiple individuals and entities with conspiracy to violate export control laws. It alleges that the defendants conspired to export a power turbine from the US to a Russian state-owned company, requiring an export license, without obtaining the necessary license from the Department of Commerce. The Russian company was on the Entity List for export restrictions. The indictment charges the defendants with conspiracy to commit offenses against the US in violating export control laws.
This document provides an overview and analysis of the RESTORE Act, which was passed in 2012 to allocate funds from legal settlements and penalties resulting from the 2010 Deepwater Horizon oil spill. It discusses how the RESTORE Act divides funds into different "pots" and compares how funds are allocated in "Home Rule" states that distribute funds directly to counties versus "non-Home Rule" states where state governments control the funds. The document argues that giving control to local counties leads to more efficient and localized project selection that better benefits affected areas.
Motion to Intervene in ET Rover Pipeline Application for Eminent Domain befor...Marcellus Drilling News
A motion by Columbus, OH law firm Goldman & Braunstein to prevent ET Rover from obtaining eminent domain to install the ET Rover pipeline without first negotiating with individual landowners. Eminent domain takes all of the bargaining power away from landowners. This motion attempts to remedy that.
Fda recall of fresenius dialysis drugs granu flo and naturalyte 3 29-2012Michael J. Evans
GranuFlo and NaturaLyte, two drugs made by Fresenius Medical Care for use during kidney dialysis, were recalled by the FDA on March 29, 2012. This is a copy of the FDA recall notice. This was the most serious type of FDA recall, a Class I recall, which means that the drug is likely to cause serious injury or death if used.
GranuFlo and NaturaLyte were recalled after they were found to have a significant risk of causing cardiac problems, heart attacks, and sudden death.
It is possible that the time to file a NaturaLyte or GranuFlo lawsuit could end on March 29, 2014, or even on some earlier date. If you suffered serious cardiac injuries or a heart attack during or after dialysis, or if you lost a family member from cardiac problems during or after dialysis, and if you don't have a lawyer, you need to contact a law firm. The injuries or death may have been caused by GranuFlo or NaturaLyte, and you may be unaware of it. There are lawyers (such as myself) who will evaluate a potential lawsuit free-of-charge. If it appears that the injuries or death may have been linked to NaturaLyte or GranuFlo, lawyers such as myself pay the cost of getting the medical records to find out if those drugs were used. If you suffered injuries or lost a loved one due to cardiac problems during or after dialysis, and this occurred before March 29, 2012, you should consider contacting a law firm immediately. Time may be quickly running out for you to take action to collect a large amount of money damages.
NaturaLyte and GranuFlo lawsuits in federal court have been consolidated into multidistrict litigation in federal court in Massachusetts. These lawsuits all claim money from the maker of GranuFlo and NaturaLyte, Fresenius Medical Care. NaturaLyte and GranuFlo were drugs used in the process of kidney dialysis. The FDA issued a Class I recall, its most serious, after it was discovered that NaturaLyte and GranuFlo could cause cardiac problems, including heart attacks and sudden death.
NaturaLyte and GranuFlo were recalled March 29, 2012. A copy of the FDA Recall Notice can be found among the documents uploaded by Michael J. Evans here on SlideShare.
Because the two dialysis drugs were presumably not used after March 29, 2013, there is some reason to believe that most, if not all, NaturaLyte and GranuFlo lawsuits could have been filed by March 30, 2012. Therefore, in states which have a two-year statute of limitations, there is an argument that the statute of limitations would run on a NaturaLyte or GranuFlo lawsuit no later than March 29, 2014. Of course, there are some states with longer statutes of limitation, and there are legal arguments, such as tolling, that may allow some people to file NaturaLyte and GranuFlo lawsuits after March 29, 2014.
It seems risky to this lawyer to wait to file a NaturaLyte or GranuFlo lawsuit. On July 29, 2013, the MDL judge entered this order setting a scheduling conference for August 30, 2013. One part of the Order that should be of particular interest to people with NaturaLyte or GranuFlo claims is this: the judge ordered all plaintiffs' attorneys to provide settlement proposals to the defendants' lawyers no later than two weeks prior to the hearing. That deadline ran on August 16, 2013. The lawyers for Fresenius Medical Care are ordered to respond to the proposals at the August 30 hearing.
If you were seriously injured by dialysis, or lost a family member due to dialysis, before the NaturaLyte and GranuFlo recall on March 29, 2013, you should have already had your possible lawsuit reviewed by a law firm which is experienced in representing injured people in pharmaceutical and medical device lawsuits. If you or your loved one experienced serious cardiac problems, including a heart attack or sudden death during or after dialysis while NaturaLyte and GranuFlo were still on the market, you may have a valuable claim for money but be unaware of it. You probably wouldn't be told by Fresenius that you or your family member were injured (or died) due to NaturaLyte or GranuFlo. You may wish to contact a law firm which is willing to spend the money to get copies of the medical records (at no cost to you) to see if NaturaLyte or GranuFlo were used. I am part of a group of law firms that handles such cases, and we would be glad to investigate your possible case of cardiac problems or death due to dialysis. If we don't collect money FOR you, we don't collect and money FROM you. It's a risk-free opportunity.
Dialysis Patients' Bill of Rights and Responsibilities - National Kidney Foun...Michael J. Evans
The document outlines the Dialysis Patients' Bill of Rights and Responsibilities as established by the National Kidney Foundation. It details 18 rights that patients have, including the right to quality care, privacy, treatment options, and information. It also lists 6 responsibilities of patients, such as being informed, following treatment plans, and fulfilling financial obligations. The rights and responsibilities are intended to promote high-quality care and positive relationships between dialysis facilities and their patients.
Safety communications fda safety communication dialysate concentrates and ...Michael J. Evans
http://dialysis-lawsuits.org has more information about dialysis patient safety and CDC protocols to guard against dialysis bloodstream infections, sepsis, and death due to septic schlock.
Safety alerts for human medical products dialysate concentrates used in hem...Michael J. Evans
This document summarizes a safety communication from the FDA regarding potential alkali dosing errors during hemodialysis treatment. The FDA issued a recall for certain dialysate concentrates that contain acetic acid or acetate, which can contribute to elevated bicarbonate levels and metabolic alkalosis in patients. Healthcare providers are advised to review the components of dialysate concentrates and be aware that metabolic alkalosis increases the risk of adverse health issues like cardiopulmonary arrest. Patients and providers are encouraged to report any adverse events to the FDA.
Fresenius Medical Care North America recalled their Naturalyte and Granuflo Acid Concentrate products used in hemodialysis treatment due to the risk of inappropriate prescription leading to metabolic alkalosis in patients. Metabolic alkalosis poses serious health risks such as low blood pressure, hypokalemia, hypoxemia, hypercapnia and cardiac arrhythmia, which could result in cardiopulmonary arrest or death if not treated properly. The recall involved liquid and powder acid concentrate products manufactured between January 2008 and June 2012.
Drug safety and availability fda drug safety communication fda investigati...Michael J. Evans
The FDA is investigating new findings that suggest incretin mimetic drugs used to treat type 2 diabetes, such as exenatide and liraglutide, may increase the risk of pancreatitis (pancreas inflammation) and pancreatic duct metaplasia (a pre-cancerous condition). The findings are based on examination of pancreatic tissue from deceased patients. The FDA is asking researchers for more details and tissue samples to further study any potential pancreatic risks. The FDA has not reached conclusions and will update the public when its review is complete.
Fresenius Medical Care North America recalled their Naturalyte and Granuflo Acid Concentrate products used in hemodialysis treatment due to the risk of inappropriate prescription leading to metabolic alkalosis in patients. Metabolic alkalosis poses serious health risks such as low blood pressure, hypokalemia, hypoxemia, hypercapnia and cardiac arrhythmia, which could result in cardiopulmonary arrest or death if not treated properly. The recall involved liquid and powder acid concentrate products manufactured between January 2008 and June 2012.
Fda warning letter 3 5-2013 to dialysis drug maker and dialysis provider Fres...Michael J. Evans
The FDA issued a warning letter to Fresenius Medical Care regarding violations found during an inspection of their Ogden, UT facility. The inspection revealed that their Optiflux Polysulfone Dialyzers were adulterated because their design validation and design verification processes did not comply with good manufacturing practice regulations. Specifically, biocompatibility testing was incomplete and additional testing was needed to evaluate dialyzer membrane effects. The company was asked to respond within 15 days detailing corrective actions to address the violations.
This document outlines Rules 23 and 23.1 of the Federal Rules of Civil Procedure regarding class action lawsuits. Rule 23 discusses the prerequisites for class certification, including numerosity, commonality, typicality and adequacy of representation. It also establishes three categories for class action certification and addresses issues related to notice, judgments, particular issues, subclasses, settlement and appeals. Rule 23.1 addresses derivative actions brought by shareholders to enforce rights of a corporation.
Joint motionforpreliminaryapprovalofbp settlementwithdeclofazariex1_4_18_2012Michael J. Evans
The Plaintiffs Steering Committee and BP Defendants jointly moved the court to (1) preliminarily approve a class action settlement, (2) schedule a fairness hearing, (3) approve and issue proposed class action settlement notice, and (4) adjourn the limitation and liability trial until after the fairness hearing. They argued that the proposed settlement is fair, reasonable and adequate, and that the notice plan complies with legal requirements. BP separately requested adjourning the trial, which the court has authority to do.
Bp settlement final_order_and_judgment_on_economic_class_settlementMichael J. Evans
This order grants final approval of the Economic and Property Damages Settlement Agreement relating to the 2010 Deepwater Horizon oil spill in the Gulf of Mexico. It confirms certification of the Economic Class for settlement purposes and confirms the appointments of class counsel, claims administrators, and trustees. The order finds that class notice was adequate, dismisses class members' related claims with prejudice, and retains jurisdiction to implement and enforce the settlement.
Bp settlement order_and_reasons_for_final_approval_of_bp_settlement Michael J. Evans
This order grants final approval of the Economic and Property Damages Settlement Agreement between BP and private plaintiffs resulting from the 2010 Deepwater Horizon oil spill. The settlement resolves economic loss and property damage claims for individuals and businesses in Gulf states and coastal areas through court-supervised programs that have already paid out over $405 million. The order describes the settlement categories, geographic scope, exclusions, lack of caps except for Seafood Compensation, and transparency of the claims framework. A fairness hearing was held on November 8, 2012 to consider final approval and objections.
This document is a status report from the Claims Administrator of the Deepwater Horizon Economic and Property Damages Settlement Agreement to the United States District Court for the Eastern District of Louisiana. It provides updates on the number of claims submitted and reviewed, the identity verification and review processes, exclusions reviews, accounting support reviews, and quality assurance reviews being conducted. The report aims to inform the Court on the current status of implementing the Settlement Agreement.
This BP settlement notice was sent to only about 500,000 business owners and others who had filed claims with BP before the settlement. BP settlement includes all people, businesses and charities in Alabama, Mississippi, Louisiana, and western Florida. BP's Notice Administrator could have bought mailing lists and sent the notice to over a million businesses and charities that are class members that might have claims, but he did not. Sending notice by mail would cost BP money to send the notice, and likely increase the number and amount of claims filed. If you are a business or charity in Alabama, you may visit http://BPOilnews.com or http://BP-Settlement-News to fill out a form to obtain a free legal review of your potential right to collect money from the BP settlement.
Bp settlement declaration_cameron_azari_bp_settlement_notice_administrator_4_...Michael J. Evans
This document is the declaration of Cameron Azari, who administered the class action notice plan for the BP Deepwater Horizon Oil Spill Settlement. It explains that Azari is an expert in legal notice and notice plan design. The declaration outlines how the target audience for the BP Settlement notice was intended to match the class definition in the Settlement Agreement. It also highlights Azari's plans to send individual notice by mail to settlement class members.
Youngest c m in India- Pema Khandu BiographyVoterMood
Pema Khandu, born on August 21, 1979, is an Indian politician and the Chief Minister of Arunachal Pradesh. He is the son of former Chief Minister of Arunachal Pradesh, Dorjee Khandu. Pema Khandu assumed office as the Chief Minister in July 2016, making him one of the youngest Chief Ministers in India at that time.
13062024_First India Newspaper Jaipur.pdfFIRST INDIA
Find Latest India News and Breaking News these days from India on Politics, Business, Entertainment, Technology, Sports, Lifestyle and Coronavirus News in India and the world over that you can't miss. For real time update Visit our social media handle. Read First India NewsPaper in your morning replace. Visit First India.
CLICK:- https://firstindia.co.in/
#First_India_NewsPaper
Essential Tools for Modern PR Business .pptxPragencyuk
Discover the essential tools and strategies for modern PR business success. Learn how to craft compelling news releases, leverage press release sites and news wires, stay updated with PR news, and integrate effective PR practices to enhance your brand's visibility and credibility. Elevate your PR efforts with our comprehensive guide.
केरल उच्च न्यायालय ने 11 जून, 2024 को मंडला पूजा में भाग लेने की अनुमति मांगने वाली 10 वर्षीय लड़की की रिट याचिका को खारिज कर दिया, जिसमें सर्वोच्च न्यायालय की एक बड़ी पीठ के समक्ष इस मुद्दे की लंबित प्रकृति पर जोर दिया गया। यह आदेश न्यायमूर्ति अनिल के. नरेंद्रन और न्यायमूर्ति हरिशंकर वी. मेनन की खंडपीठ द्वारा पारित किया गया
1. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 1 of 40
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF FLORIDA
PANAMA CITY DIVISION
STATE OF FLORIDA,
Plaintiff,
vs.
BP EXPLORATION & PRODUCTION CASE NO.:
INC., BP p.l.c., BP AMERICA
PRODUCTION COMPANY, and
HALLIBURTON ENERGY
SERVICES, INC.,
Defendants.
/
COMPLAINT
Plaintiff, STATE OF FLORIDA (“Florida” or “State”), sues
Defendants, BP Exploration and Production Inc., BP p.l.c., BP America
Production Company, and Halliburton Energy Services, Inc., for loss of tax
revenue and income and other economic damages or losses as a result of
the oil spill following the sinking of the oil rig Deepwater Horizon in the
Gulf of Mexico on or about April 20, 2010, and alleges as follows :1
1
Plaintiff is aware that certain Transocean entities commenced an action under the
Limitation of Shipowners Liability Act. Subject to a determination as to the Transocean
entities’ ability to limit liability, Plaintiff reserves the right to amend this Complaint to
add additional claims and parties.
2. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 2 of 40
Introduction
1. In April 2010, the actions of BP Exploration and Production,
Inc., BP, p.l.c., and Halliburton Energy Services, Inc. resulted in the worst
oil spill in American history, with the unfettered release of millions of
gallons of hydrocarbons directly into the Gulf of Mexico. As a result of the
uncontrolled well event, blowout, multiple explosions, and fires, millions of
barrels of oil were discharged into and upon waters of the Gulf of Mexico
and adjoining shorelines of the United States, including the pristine beaches,
shorelines, and estuaries of Florida. The full extent of the impact of the spill
is not yet known and may not be known for several years.
2. This action arises out of the economic losses suffered by
Florida due to the release of millions of gallons of hydrocarbons into the
Gulf of Mexico from the oil well drilled in Mississippi Canyon Block 252
(hereinafter referred to as the “Macondo Well”) following the explosions
and fire aboard the MODU Deepwater Horizon that resulted in its sinking
and the subsequent release of hydrocarbons (the “Spill”). Oil flowed into
the Gulf of Mexico unchecked for months.
3. Florida’s tourism-centered economy suffered greatly from the
effects of the Spill. Florida receives over 85,000,000 visitors per year and
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3. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 3 of 40
generates more than $80 Billion dollars in tourism-dependent revenue.
Without this level of tourism, Florida suffers, as do many of the local people
and communities who are supported by it.
4. A major part of the Florida economy’s tourism focus is its
beautiful beaches. Florida has 1,200 miles of coastline, which is more than
all of the other Gulf Coast states combined. In this context, the extent of
Florida’s coastline equals greater economic damages both during and after
the Spill along with an exponentially higher risk of harm from any re-oiling
event or other possible future consequences from the Spill.
5. As a result, Florida has sustained, and will continue to sustain,
significant economic losses.
Jurisdiction and Venue
6. This Court has jurisdiction under 28 U.S.C. §§ 1331 and 1333,
the Oil Pollution Act of 1990 (“OPA”), 33 U.S.C. § 2717(b), and 43 U.S.C.
§ 1349(b)(1).
7. This Court also has supplemental jurisdiction pursuant to 28
U.S.C. § 1367 over the pendent state law claims because those claims are so
related to the federal claims in the action that they form part of the same case
or controversy.
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4. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 4 of 40
8. Venue is appropriate in this Court pursuant to 28 U.S.C. §
1391(b) (venue generally) and 33 U.S.C. § 2717(b) (OPA).
Parties
9. Florida is and was at all material times engaged in the
implementation and management of the governmental infrastructure for its
citizens.
10. BP Exploration & Production Inc. (“BPXP”) is and was at all
material times a business organized under the laws of Delaware with its
principal place of business in Warrenville, Illinois and with its principal
purpose being oil and gas exploration and production. BPXP is registered to
engage in business in Florida, maintains continuous and systemic contacts in
Florida, and is subject to personal jurisdiction in Florida. BPXP was
designated a Responsible Party as that term is contemplated under the Oil
Pollution Act, 33 U.S.C. § 2701(32) and Fla. Stat. §376.031(20).
11. BP p.l.c. (collectively with BPXP referred to herein as “BP”) is
and was at all material times a British multinational oil and gas company
headquartered in London, United Kingdom. BP p.l.c. maintains continuous
and systemic contacts in Florida and is subject to personal jurisdiction in
Florida. BP p.l.c. publicly acknowledged that it would cover or otherwise
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5. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 5 of 40
make funds available for damages assessed against BPXP as a result of the
Spill, including, but not limited to, damages under OPA.
12. BP America Production Company (“BP America”) is and was
at all material times a business organized under the laws of Delaware with
its principal place of business in Houston, Texas. BP America contracted
with Transocean Ltd. for the drilling of the Macondo Well by the MODU
Deepwater Horizon. BP America is registered to conduct business in
Florida, maintains continuous and systemic contacts in Florida, and is
subject to personal jurisdiction in Florida.
13. Halliburton Energy Services, Inc. (“Halliburton”) is and was at
all material times a Delaware corporation with its principal places of
business in Houston, Texas and Dubai, United Arab Emirates and was
authorized to do business in Florida, maintains continuous and systemic
contacts in Florida, and may be found in Florida. Halliburton was engaged
in cementing operations aboard Deepwater Horizon at the Macondo Well.
Halliburton is and was at all material times in the business of designing and
implementing cement mixes for use in various applications, including, but
not limited to, deepwater oil exploration activities.
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6. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 6 of 40
14. Sperry Drilling Services (“Sperry,” together with Halliburton
collectively referred to as “Halliburton”) is a division of Halliburton and was
responsible for mudlogging personnel and equipment on the MODU
Deepwater Horizon, including downhole drilling tools. Sperry mudlogging
personnel were partially responsible for monitoring the well, including mud
pit fluid levels, mud flow in and out of the well, mud gas levels, and
pressure fluctuations.
15. At all material times prior to the Spill, the MODU Deepwater
Horizon was a vessel and an offshore facility, capable of being used to drill
offshore wells, flagged under the laws of the Republic of the Marshall
Islands.
16. At all times material hereto, Deepwater Horizon had as part of
its operating equipment and appurtenances a Blowout Preventer (“BOP”)
and a Lower Marine Riser Package (“LMRP”) (together the “BOP stack”), a
marine riser and associated piping, and other equipment, all of which
constitute, inter alia, “appurtenances” under Admiralty law.
Factual Allegations
17. On or about May 8, 2008, BPXP, as lessee, executed the
document known as the “Oil and Gas Lease of Submerged Lands under the
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7. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 7 of 40
Outer Continental Shelf Lands Act,” “Serial number OCS-G 32306”
(hereinafter the “Lease”), pertaining to “All of Block 252, Mississippi
Canyon, OCS Official Protraction Diagram, NH 16-10.”
18. On or about May 14, 2008, the United States, by and through
the Minerals Management Service (hereinafter “MMS”), as lessor, executed
the Lease, which became effective on June 1, 2008.
19. As lessee of the Lease, BPXP at all material times was subject
to, inter alia, the requirements of 30 C.F.R. § 250.400 and the regulations
specified therein.
20. On or about October 2009, drilling began at the Macondo Well.
21. At all times material herein, the Macondo Well was an
"offshore facility" within the meaning of OPA, 33 U.S.C. §§ 2701 et seq.
22. Beginning in or about February 2010, the MODU Deepwater
Horizon was utilized for the purpose of continuing the drilling of the
Macondo Well. Drilling of the Macondo Well using the Deepwater Horizon
continued in February 2010 and through March and a portion of April 2010.
23. As of April 20, 2010, various sub-sea equipment and
components of the Macondo Well had been installed on or below the
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8. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 8 of 40
seafloor of the Outer Continental Shelf, including, but not limited to, the
well casing and the well head.
24. As of April 20, 2010, Deepwater Horizon and various
appurtenances of the Deepwater Horizon, including, but not limited to, the
BOP stack and marine riser, were installed on and/or attached to the seafloor
of the Outer Continental Shelf, purportedly for purposes of, inter alia,
operation of the Macondo Well, including well control.
25. On or about April 20, 2010, the Macondo Well experienced an
uncontrolled well event and blowout of hydrocarbons, including oil and
natural gas.
26. The loss of well control was due to the failure of mechanical
and cement barriers to seal off the well against the influx of highly
pressurized hydrocarbons from the reservoirs surrounding the bottom of the
well. The many indications that hydrocarbons were leaking into the well
were misinterpreted and/or overlooked by BP and Halliburton for about 50
minutes prior to the blowout. Once the hydrocarbons reached the vessel
decks, fire and gas prevention and alarm systems on the vessel failed to warn
the crew and prevent ignition of a fire. The vessel’s subsea BOP also failed
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9. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 9 of 40
to seal the well and stop the flow of hydrocarbons fueling the fire, which
exacerbated the disaster.
27. After Deepwater Horizon sank, oil and gas gushed out of the
damaged well and into the Gulf of Mexico for approximately 12 weeks,
fouling the environment, damaging and contaminating real and personal
property, and doing immense and long-lasting economic damage.
28. Deepwater Horizon utilized a mud gas separator to remove
hydrocarbon gas from the mud utilized for drilling purposes. The mud gas
separator is and was at all material times a low-pressure system. BP and
Halliburton knew or should have known the design limits of the mud gas
separator would have been exceeded by the expanding and accelerating
hydrocarbon flow back to Deepwater Horizon and, in fact, were exceeded.
29. The mud gas separator gas outlet vent was positioned in such a
manner as to direct potentially concentrated levels of gaseous fumes onto or
below the deck of Deepwater Horizon and possibly into confined spaces,
allowing for the rig to be enveloped in a flammable mixture of gases.
30. The first indications of the flow of hydrocarbons from the well
were observable in the real-time data recorded on Deepwater Horizon. BP
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10. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 10 of 40
and Halliburton either did not observe or did not recognize the indications of
flow until after hydrocarbons entered the riser.
31. Neither BP’s nor Halliburton’s protocols fully addressed how to
respond to a high-flow emergency situation after the loss of well control.
32. Halliburton was hired to design and implement a cement slurry
mix or combination of mixes capable of properly sealing the Macondo Well
at a depth of approximately 5,000 feet below the sea surface.
33. The principal purpose of the cement slurry design mix that
Halliburton was responsible for developing and implementing was to seal
the Macondo Well to such an extent as to prevent the escape of
hydrocarbons from the wellbore that could cause personal injury, death,
property, and/or environmental damage.
34. Halliburton designed a number of cement slurry mixes,
including a foam cement slurry, to be used to seal the Macondo Well.
35. Halliburton conducted numerous tests relating to the foam
cement slurry design mix intended to be used to seal the Macondo Well.
The test results of the foam design slurry mix revealed, inter alia, an
insufficient, non-representative nitrogen volume in the design slurry,
indicating that the foam cement slurry was likely unstable and would result
10
11. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 11 of 40
in nitrogen breakout. Additionally, the test results revealed that the low
yield point of the foam cement slurry mix could or would lead to difficulty
in foam stability, that the use of a defoamer could or would lead to difficulty
in foam stability, and that the lack of an additive controlling fluid loss could
or would allow fluid to be lost at a rate greater than that recommended and
accepted in industry practice.
36. Despite the test results of the design slurry, Halliburton made
no recommendations for changing, altering or otherwise modifying the foam
cement slurry mix design.
37. Halliburton recommended and, in fact, utilized the foam cement
slurry mix design that revealed the numerous aforementioned flaws during
the testing protocol without changing, altering or otherwise modifying the
mix design prior to its implementation.
38. As a result of the inadequate, insufficient, and demonstrably
faulty mix design, the nitrified foam slurry suffered nitrogen breakout,
nitrogen migration, and incorrect cement density, all of which contributed to
the failure to properly achieve zonal isolation of hydrocarbons.
39. Although the BOP was designed to automatically actuate in the
event of a sudden loss of pressure, the automatic mode function failed to
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12. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 12 of 40
operate the BOP’s blind shear ram upon the loss of hydrostatic control over
the flow of hydrocarbons in the Macondo well. The response teams were
unable to manually activate Deepwater Horizon’s BOP to prevent the
continuous flow of hydrocarbons from the Macondo well.
40. The BOP utilized a series of 9-volt battery packs to operate the
automatic mode function actuator in each pod and solenoids to relay signals
to the various mechanical components of the BOP.
41. At all material times, BP knew or should have known that the
manufacturer recommended replacement of the batteries in the battery packs
at least once per year or after 33 actuations, whichever occurred first.
42. The maintenance records reveal that BP did not replace the
batteries in the battery packs per the manufacturer’s recommendations.
43. The batteries had an insufficient charge to activate the
automatic mode function and actuate the blind shear ram. The failure to
actuate the blind shear ram prevented the wellbore from being sealed at the
location of the BOP.
44. The BOP utilized solenoid valves to relay actuation of the
various sealing methods in the BOP.
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13. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 13 of 40
45. Solenoid valve 103, which was required to operate the high-
pressure blind shear ram close function, had a non-original equipment
manufacturer electrical connector installed and was found to be defective.
Solenoid valve 3A, which was required to increase the upper annular
preventer regulator pressure, was also found to be defective.
46. BP knew or should have known that failing to properly
maintain these essential elements of the BOP would render the BOP
inoperative and/or unreliable.
47. The failure of the solenoid valves identified herein prevented
the closure of the blind shear ram and the activation of the upper annular
preventer, thereby allowing hydrocarbons to continue to escape from the
wellbore.
48. As a result of the lack of hydrostatic control over the
hydrocarbons and the failure of the BOP to activate, there were explosions
and fires aboard Deepwater Horizon that led to its sinking. As Deepwater
Horizon sank to the seafloor, the attached riser bent and broke, allowing
hydrocarbons to escape from the broken end of the riser and two additional
places along its length.
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49. In violation of federal regulations, including, but not limited to,
30 C.F.R. § 250.401, BP and Halliburton failed, inter alia, to take necessary
precautions to keep the Macondo Well under control.
50. In violation of federal regulations, including, but not limited to,
30 C.F.R. § 250.401, BP and Halliburton failed, inter alia, to use the best
available and safest drilling technology to monitor and evaluate the
Macondo Well’s conditions and to minimize the potential for the Macondo
Well to flow or kick.
51. In violation of federal regulations, including, but not limited to,
30 C.F.R. § 250.401, BP and Halliburton failed, inter alia, to fulfill its
respective responsibilities to maintain well control of the Macondo Well.
52. In violation of federal regulations, including, but not limited to,
30 C.F.R. § 250.401, BP and Halliburton failed, inter alia, at times relevant
herein to maintain continuous surveillance on the rig floor.
53. In violation of federal regulations, including, but not limited to,
30 C.F.R. § 250.401, BP and Halliburton failed, inter alia, to maintain
equipment and materials, including, but not limited to, the BOP stack, that
were available and necessary to ensure the safety and protection of
personnel, equipment, natural resources, and the environment.
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54. BP and Halliburton caused and/or contributed to the Spill by
failing to assure well control of the Macondo Well through, inter alia,
actions, corporate actions, and/or corporate practices of disregarding federal
regulations, as evidenced by various safety and other audits of Deepwater
Horizon, reflecting the known failure, prior to the Spill, to properly design,
install, maintain, repair, and operate equipment intended to prevent personal
injury, loss of life, harm to the environment, and disasters like the Spill.
55. BP and Halliburton caused and/or contributed to the Spill by
failing to assure well control of the Macondo Well through, inter alia:
a. Failing to assure that well control was maintained by
proper and adequate cementing of the Macondo Well;
b. Failing to assure that well control was maintained by
mechanical barriers, including, but not limited to, the BOP stack;
c. Failing to assure that well control was maintained by
proper and adequate inspection and maintenance of the BOP stack;
d. Failing to assure that well control was maintained by
proper and adequate pressure testing;
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e. Failing to assure that well control was maintained by the
use of appropriate fluids to maintain hydrostatic pressure on the
wellbore;
f. Failing to assure that well control was maintained by
proper and adequate well monitoring;
g. Failing to assure that, once well control initially was lost,
well control was regained by proper and adequate well control
response;
h. Failing to assure that, once well control initially was lost,
well control was regained by proper and adequate surface containment
and overboard discharge and diversion of hydrocarbons; and
i. Failing to assure that, once well control initially was lost,
well control was regained by proper and adequate BOP stack
emergency operations.
56. As a result of the April 20, 2010, uncontrolled well event and
blowout, multiple explosions and fires occurred aboard Deepwater Horizon.
57. As a result of the discharge of oil and methane gas and the
resulting multiple explosions and fires that occurred aboard Deepwater
Horizon, equipment was damaged and/or destroyed, which equipment could
16
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have prevented and/or limited further damage and injury, including the
prevention and/or limitation of discharge of oil into and upon waters of the
Gulf of Mexico and adjoining shorelines of the United States, including
Florida.
58. As a result of the uncontrolled well event, blowout, multiple
explosions, and fires, millions of barrels of oil were discharged from the
Macondo Well, associated equipment, the BOP stack, the marine riser, and
Deepwater Horizon into and upon waters of the Gulf of Mexico and
adjoining shorelines of the United States, including Florida.
59. The Spill resulted from one or more of the following: acts, joint
acts, omissions, fault, negligence, gross negligence, willful misconduct,
and/or breach of federal safety and/or operating and/or construction
regulations by BP, Halliburton and/or their respective agents, servants,
employees, crew, contractors and/or subcontractors with whom said
Defendants had contractual relationships.
60. To date, the Macondo Well has been capped to prevent the
continued flow of hydrocarbons into the Gulf of Mexico. However, the
hydrocarbons that escaped prior to the well’s capping made landfall along
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the Gulf coastline in Florida, and much of it remains in the Gulf of Mexico
and on the seafloor.
61. The fire and explosion on Deepwater Horizon, its sinking, and
the resulting release of hydrocarbons were caused by the combined and
concurring improper acts and omissions of BP and Halliburton, which
renders them jointly and severally liable for all of the economic damages
suffered by Florida.
62. BP and Halliburton knew or should have known of the dangers
and risks associated with deepwater drilling and failed to take appropriate
measures to prevent foreseeable damage to Florida.
63. The escaped hydrocarbons have caused, and will continue in the
future to cause, a dangerous and harmful contamination of the Gulf of
Mexico.
64. The pristine nature of the Gulf of Mexico and its surrounding
marine and estuarine environments attracts numerous patrons, tourists, and
visitors to Florida; however, the release of hydrocarbons has tainted the Gulf
of Mexico, thereby causing many of the would-be patrons, tourists, and
visitors to travel to and engage in commercial activities in other, less Gulf-
oriented locales, if at all. Indeed, Florida relies on the pristine nature of the
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Gulf of Mexico as the source for much of the attraction of patrons, tourists,
and visitors.
65. Due to the released hydrocarbons and their contamination of the
Gulf of Mexico, Florida suffered a dramatic decrease in the number of
people visiting and patronizing the State. Accordingly, Florida has lost
substantial tax revenues, including, but not limited to, lost Business Tax
Receipts measured by gross sales of Merchants; lost Public Service Tax
receipts; lost Communication Services Tax; and lost net revenue.
66. The Spill and the resulting contamination have caused and will
continue to cause loss of revenue to individuals and businesses, thereby
causing a loss of revenue to Florida.
67. The Spill dealt a devastating blow to tourism in the region and
the individuals and businesses that ordinarily thrive on tourism and tourism-
related business.
68. The foregoing losses in the private sector have caused severe
damage to Florida in the form of lost income and tax revenues.
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69. The oil impacted, injured, and damaged the waters, shores, and
estuaries of Florida leading to the economic losses that are being sought in
this action.2
70. As the contamination of the Gulf of Mexico persists, Florida
will suffer further lost revenues in the future.
71. There are many other potential effects from the released
hydrocarbons that have not yet become known and Florida reserves the right
to amend this Complaint once additional information becomes available.
COUNT I
(Strict Liability Under OPA, 33 U.S.C. §§ 2702(b)(2)(D) Against BPXP
and BP p.l.c. for Lost Revenues)
72. Florida realleges the allegations of paragraphs 1 through 27 and
63 through 71 of this Complaint and further alleges:
73. BPXP was designated as a “Responsible Party” as that term is
defined in OPA, 33 U.S.C. § 2701(32).
74. OPA is a strict liability statute with the “Responsible Party”
liable for the damages specified therein. See 33 U.S.C. § 2702(a).
2
The claim for the damage to Florida’s natural resources is vested in the State trustee by
OPA section 2702(b)(2)(A). The claims in this lawsuit are limited to the economic losses
suffered due to the injury to and destruction of natural resources.
20
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75. As a result of the Spill, Florida sustained and will sustain
“damages,” within the meaning of OPA, 33 U.S.C. § 2702(b).
76. Florida has satisfied the claims presentment requirement under
OPA, 33 U.S.C. § 2713.
77. Florida derives much of its revenue from economic activity
related to its waters, estuarine environments, pristine beaches, and marine
life.
78. The Spill permitted oil to impact Florida’s territorial waters and
wash upon Florida’s beaches, thereby causing would-be visitors to avoid
visiting the State.
79. As a result of the Spill, Florida suffered the loss of taxes and
fees, including but not limited to sales and use taxes; corporate taxes;
documentary stamp taxes; cigarette surcharges; cigarette excise taxes; beer,
wine, and liquor taxes; fuel taxes; rental car surcharges; and utility taxes and
receipts, and Florida will continue to suffer such losses in the future. Such
damages are recoverable under OPA, 33 U.S.C. § 2702(b)(2)(D).
COUNT II
(Negligence Under Florida Common Law Against All Defendants)
80. Florida realleges the allegations of paragraphs 1 through 71 of
this Complaint and further alleges:
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81. The explosions, fire, sinking of Deepwater Horizon, release of
hydrocarbons, and resulting contamination were caused or contributed to by
the joint negligence of Defendants in the following respects, among others
that will be revealed during further investigation and discovery:
a. Failing to properly maintain, equip and/or operate
Deepwater Horizon;
b. Operating Deepwater Horizon in such a manner as to
cause explosions and fires onboard, causing it to sink and result in the
release of hydrocarbons;
c. Failing to properly inspect and equip Deepwater Horizon
with the appropriate equipment and personnel;
d. Acting in a careless, reckless, and negligent manner;
e. Failing to promulgate, implement, and enforce
appropriate rules and regulations to ensure the safe operations of
Deepwater Horizon, which could and would have prevented the
disaster;
f. Failing to take appropriate action to avoid, mitigate or
remedy the disaster;
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g. Carelessly, recklessly, and negligently implementing
policies and procedures for safe conduct during offshore operations in
the Gulf of Mexico;
h. Failing to ensure that Deepwater Horizon and its
equipment were in proper working order and/or were free from
defects;
i. Failing to timely warn;
j. Failing to timely control the release of hydrocarbons
from the Macondo Well;
k. Failing to provide appropriate and effective disaster
prevention equipment; and
l. Acting with clear disregard for the life, personal
property, real property and/or environment in or around the Gulf of
Mexico and its coastal, marine, and estuarine environments and the
livelihoods of those who relied on the same.
82. The economic injuries to Florida were also caused by or
aggravated by the fact that Defendants failed to take necessary actions to
mitigate the damages associated with the release of hydrocarbons.
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83. Furthermore, the disaster would not have occurred had the
Defendants exercised a high degree of care. Florida, therefore, pleads the
doctrine of res ipsa loquitur.
84. The negligence caused the release of hydrocarbons and
contamination of the Gulf of Mexico, directly and proximately causing
Florida to suffer economic damages exceeding the jurisdictional
requirements of this Court as can nearly be determined at this time, which
are continuing to accrue.
85. Florida is entitled to a judgment against Defendants jointly and
severally for the economic damages suffered as a result of Defendants’
careless, reckless, and negligent acts and/or omissions in an amount to be
determined by the trier of fact.
COUNT III
(Negligence Per Se Against All Defendants under Florida Law)
86. Florida realleges the allegations of paragraphs 1 through 71 of
this Complaint and further alleges:
87. Defendants’ conduct with regard to the manufacture,
maintenance, operation and/or utilization of drilling operations and oil rigs
such as Deepwater Horizon is governed by numerous state and federal laws,
and permits issued under the authority of these laws.
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88. These laws and permits create statutory standards that are
intended to protect and benefit Florida and others.
89. Defendants’ violations of these statutory standards constitute
negligence per se under Florida law.
90. Defendants’ violations of these statutory standards proximately
caused Florida economic damages, warranting an award of compensatory
damages against Defendants jointly and severally.
COUNT IV
(Gross Negligence Under the General Maritime Law Against All
Defendants)
91. Florida realleges the allegations of paragraphs 1 through 71 of
this Complaint and further alleges:
92. Defendants owed a heightened duty to Florida to exercise
reasonable care in the manufacture, installation, maintenance, and operation
of Deepwater Horizon and its appurtenances.
93. Defendants had a heightened duty of care to Florida because of
the inherent risk and great danger associated with deepwater drilling and the
cementing work such as that Deepwater Horizon was performing at the time
of the explosions and fires.
25
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94. Defendants breached their legal duty to Florida and failed to
exercise reasonable care, and acted with reckless, willful, and wanton
disregard for the business of Florida in the negligent manufacture,
installation, maintenance and/or operation of Deepwater Horizon and its
appurtenances.
95. Defendants knew or should have known that their wanton or
reckless conduct would result in a foreseeable blowout and release of
hydrocarbons, causing personal injuries, deaths, property and/or
contamination of the Gulf of Mexico. Furthermore, it is and was at all
material times foreseeable for the blowout and release of hydrocarbons to
cause damage to the economic and business interests of Florida given its
proximity to the area affected by the Spill.
96. As a direct and proximate result of Defendants’ wanton or
reckless conduct, Florida has suffered legal injury and damages for which
Defendants are liable jointly and severally, including but not limited to, loss
of income, loss of profits, and other economic losses.
COUNT V
(Gross Negligence Under Florida Law Against All Defendants)
97. Florida realleges the allegations of paragraphs 1 through 71 of
this Complaint and further alleges:
26
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98. Defendants owed a heightened duty of care to Florida because
of the inherent risk and great danger associated with deepwater drilling and
the cementing work such as that Deepwater Horizon was performing in the
vicinity of Florida’s coast at the time of the explosions and fires.
99. Defendants breached their legal duty to Florida and failed to
exercise reasonable care and acted with reckless, willful, and wanton
disregard for the business of Florida in the negligent manufacture,
installation, maintenance and/or operation of Deepwater Horizon and its
appurtenances.
100. Defendants knew or should have known that their reckless
conduct would result in a foreseeable blowout and release of hydrocarbons,
causing personal injuries, deaths, property and/or contamination of the Gulf
of Mexico. Furthermore, it is and was at all material times foreseeable for
the blowout and release of hydrocarbons to cause damage to the economic
and business interests of Florida given its proximity to the area affected by
the Spill.
101. As a direct and proximate result of Defendants’ reckless
conduct, Florida has suffered legal injury and damages for which Defendants
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are jointly and severally liable, including but not limited to, loss of income,
loss of profits, and other economic losses.
COUNT VI
(Strict Liability for Abnormally Dangerous Activity Under Florida Law
Against All Defendants)
102. Florida realleges the allegations of paragraphs 1 through 71 of
this Complaint and further alleges:
103. Defendants were engaged in abnormally dangerous and/or
ultrahazardous activities.
104. Defendants’ activities resulted in explosions, fires, and release
of hydrocarbons from the Macondo Well, which:
a. Created a high degree of risk of harm to others, and
particularly to Florida;
b. Created a risk involving a likelihood that the harm
threatened by Defendants’ activities would be great and/or
unwarranted;
c. Were not a matter of common usage;
d. Were inappropriate to the place that they were being
carried on, in that they constituted an unnatural use of the waters of
the Gulf of Mexico, which imposed an unusual and extraordinary risk
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of harm to Florida, which provides governmental and municipal
services to patrons, residents, tourists, and visitors who frequent the
Gulf of Mexico and/or its coastline in or around the State of Florida.
Additionally, Florida provides many of the resources that contribute to
the maintenance of the pristine nature of the Gulf of Mexico and/or its
coastline.
105. As a direct and proximate result of Defendants’ conduct in
engaging in the abnormally dangerous and/or ultrahazardous activities as
alleged herein, substantial quantities of hydrocarbons escaped from the
Macondo Well. This identified and realized harm to Florida is that type of
risk that makes Defendants’ activities abnormally dangerous and/or
ultrahazardous.
106. Florida is entitled to a judgment finding Defendants strictly
liable for the economic damages suffered as a result of Defendants’
abnormally dangerous and/or ultrahazardous activities and awarding Florida
adequate compensation in an amount to be determined by the trier of fact.
COUNT VII
(Trespass Under Florida Law Against All Defendants)
107. Florida realleges the allegations of paragraphs 1 through 71 of
this Complaint and further alleges:
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108. Florida is and was at all material times the owner and/or
possessor of real property located along the coastline of the Gulf of Mexico
and its adjacent marine and estuarine environments, to wit, numerous public
beach access ways connecting improved public rights-of-way with the sandy
shore and waters of the Gulf of Mexico.
109. Defendants’ grossly negligent and/or reckless conduct resulted
in the deposit of hydrocarbons released from the Macondo Well into or onto
the real property owned and/or possessed by Florida located within the
jurisdictional reaches of this Court.
110. Defendants’ grossly negligent and/or reckless conduct has
directly and proximately resulted in a disturbance in Florida’s possession,
use, and enjoyment of its ownership interest in or possession of the property,
and diminished economic activity.
111. As a direct and proximate result of Defendants’ grossly
negligent and/or reckless conduct, Florida has suffered interference with the
use and enjoyment of its property, including, but not limited to, loss of tax
revenues and other economic damages.
30
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112. Defendants’ grossly negligent and/or reckless conduct entitles
Florida to punitive and/or exemplary damages in addition to the actual
damages alleged above.
113. By reason of the foregoing, Florida has incurred economic
damages and is entitled to compensatory and punitive damages in an amount
to be determined by the trier of fact.
COUNT VIII
(Nuisance Per Se Under Florida Law Against All Defendants)
114. Florida realleges the allegations of paragraphs 1 through 71 of
this Complaint and further alleges:
115. Defendants have engaged in conduct that has annoyed, injured
and/or endangered the comfort and/or welfare of Florida.
116. Defendants’ conduct has directly and proximately resulted in
unreasonable, unwarrantable and/or unlawful interference with or has
obstructed and/or rendered insecure Florida’s use and enjoyment of its
property.
117. Based on the foregoing, Defendants are jointly and severally
liable for the wrong and injury done thereby.
118. At all material times, Defendants’ conduct constituted a
nuisance per se under Florida law.
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119. As a direct and proximate result of the unreasonable,
unwarrantable and/or unlawful conduct of Defendants, Florida has suffered
interference with the use and enjoyment of its property, including, but not
limited to loss of tax revenues and other economic damages.
120. Florida is entitled to a judgment against Defendants for the
economic damages suffered as a result of Defendants’ conduct in an amount
to be determined by the trier of fact.
COUNT IX
(Punitive Damages Under the General Maritime Law Against BPXP)
121. Florida realleges the allegations of paragraphs 1 through 71 and
92 through 96 of this Complaint and further alleges:
122. BPXP owned a leasehold interest in the Macondo Well and
oversaw the drilling activities at the site.
123. BPXP neglected to ensure the safety of its operations by, inter
alia, failing to properly maintain the BOP stack, failing to monitor the
wellhead pressures, and failing to prevent the unabated flow of hydrocarbons
into the Gulf of Mexico.
124. The foregoing allegations demonstrate wanton, reckless, and
grossly negligent conduct.
32
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125. On or about November 16, 2012, BPXP pled guilty to certain
criminal charges brought by the United States for actions leading up to,
handling of, and arising out of the Spill.
126. BPXP’s guilty plea is prima facie evidence of its wanton,
reckless, and grossly negligent conduct.
127. BPXP’s guilty plea demonstrates its acceptance of the
allegations of wrongdoing against it. The charges that BPXP pled guilty to
warrant punitive damages such that future parties are dissuaded from
engaging in the same or similar wanton, reckless, and grossly negligent
conduct.
128. Accordingly, under the General Maritime Law (including, but
not limited to, by virtue of the Admiralty Extension Act), Florida is entitled
to an award of punitive damages in an amount to be determined at trial.
COUNT X
(Punitive Damages Under Florida Law Against BPXP)
129. Florida realleges the allegations of paragraphs 1 through 71 and
98 through 101 of this Complaint and further alleges:
130. BPXP owned a leasehold interest in the Macondo Well and
oversaw the drilling activities at the site.
33
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131. BPXP neglected to ensure the safety of its operations by, inter
alia, failing to properly maintain the BOP stack, failing to monitor the
wellhead pressures, and failing to prevent the unabated flow of hydrocarbons
into the Gulf of Mexico.
132. The foregoing allegations demonstrate wanton, reckless, and
grossly negligent conduct.
133. On or about November 16, 2012, BPXP pled guilty to certain
criminal charges brought by the United States for actions leading up to,
handling of, and arising out of the Spill.
134. BPXP’s guilty plea is prima facie evidence of its wanton,
reckless, and grossly negligent conduct.
135. BPXP’s guilty plea demonstrates its acceptance of the
allegations of wrongdoing against it. The charges that BPXP pled guilty to
warrant punitive damages such that future parties are dissuaded from
engaging in the same or similar wanton, reckless, and grossly negligent
conduct.
136. Accordingly, under applicable State Law, Florida is entitled to
an award of punitive damages in an amount to be determined at trial.
34
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COUNT XI
(Punitive Damages Under the General Maritime Law Against All
Defendants)
137. Florida realleges the allegations of paragraphs 1 through 71 and
92 through 96 of this Complaint and further alleges:
138. BP and Halliburton owned leasehold or other financial interests
in the Macondo Well. BP oversaw and was responsible for the drilling
activities at the site. Halliburton designed the foam slurry that was intended
to maintain the wellhead integrity.
139. BP neglected to ensure the safety of its operations by, inter alia,
failing to properly maintain the BOP stack, failing to monitor the wellhead
pressures, and failing to prevent the unabated flow of hydrocarbons into the
Gulf of Mexico.
140. Halliburton employed a faulty mix design that it knew was
inadequate to maintain the integrity of the wellhead.
141. The foregoing allegations demonstrate wanton, reckless, and
grossly negligent conduct under the General Maritime Law.
142. Due to the wanton, reckless, and grossly negligent conduct of
the Defendants, Florida suffered irreparable harm, the extent of which can
only be demonstrated through an award of punitive damages.
35
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143. Accordingly, under the General Maritime Law (including, but
not limited to, by virtue of the Admiralty Extension Act), Florida is entitled
to an award of punitive damages in an amount to be determined at trial.
COUNT XII
(Punitive Damages Under Florida Law Against All Defendants)
144. Florida realleges the allegations of paragraphs 1 through 71 and
98 through 101 of this Complaint and further alleges:
145. BP and Halliburton owned leasehold or other financial interests
in the Macondo Well. BP oversaw and was responsible for the drilling
activities at the site. Halliburton designed the foam slurry that was intended
to maintain the wellhead integrity.
146. BP neglected to ensure the safety of its operations by, inter alia,
failing to properly maintain the BOP stack, failing to monitor the wellhead
pressures, and failing to prevent the unabated flow of hydrocarbons into the
Gulf of Mexico.
147. Halliburton employed a faulty mix design that it knew was
inadequate to maintain the integrity of the wellhead.
148. The foregoing allegations demonstrate wanton, reckless, and
grossly negligent conduct under Florida law.
36
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149. Due to the wanton, reckless, and grossly negligent conduct of
the Defendants, Florida suffered irreparable harm, the extent of which can
only be demonstrated through an award of punitive damages.
150. Accordingly, under applicable State Law, Florida is entitled to
an award of punitive damages in an amount to be determined at trial.
PRAYER FOR RELIEF
WHEREFORE, the State of Florida demands judgment against
Defendants, jointly and severally, as follows:
A. Economic and compensatory damages in amounts to be
determined at trial;
B. Statutory damages;
C. Statutory penalties;
D. Pre-judgment and post-judgment interest at the maximum rate
allowable by law;
E. Punitive damages in an amount to be determined at trial;
F. Attorneys’ fees in those claims stated above that provide for
such recovery;
G. Costs; and
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H. Such other and further relief available under all applicable state
and federal laws and any relief this honorable Court deems just and
appropriate.
DEMAND FOR JURY TRIAL
Under Fed. R. Civ. P. 38(b), the Sate of Florida hereby demands trial
by jury.
PAMELA JO BONDI
ATTORNEY GENERAL
STATE OF FLORIDA
BY: s/ Russell S. Kent
RUSSELL S. KENT
Special Counsel for Litigation
Florida Bar No. 0020257
E-Mail: russell.kent@myfloridalegal.com
Office of the Attorney General
The Capitol, PL-01
Tallahassee, FL 32399-1050
Telephone: (850) 414-3854
PATRICIA A. CONNERS
Associate Deputy Attorney General
Florida Bar No. 361275
Email: Trish.Conners@myfloridalegal.com
Office of the Attorney General
The Capitol, PL-01
Tallahassee, FL 32399-1050
Telephone: (850) 245-0140
-and-
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CARL R. NELSON
Florida Bar No: 0280186
Email: cnelson@fowlerwhite.com
FOWLER WHITE BOGGS P.A.
P.O. Box 1438
Tampa, FL 33601-1438
Telephone: (813) 228-7411
S. DRAKE MARTIN
Florida Bar No: 0090479
Email: drakemartin@nixlawfirm.com
Nix Patterson & Roach, LLP
1701 E. County Hwy 30-A, Suite 201-B
Santa Rosa Beach, FL 32459
Telephone: (850) 231-4028
LOUIS B. (“BRADY”) PADDOCK
Texas Bar No: 00791394
Arkansas Bar No: 93135
Louisiana Bar No. 28711
Email: bpaddock@nixlawfirm.com
Nix, Patterson & Roach, LLP
2900 St. Michael Drive, Suite 500
Texarkana, TX 75503-5211
Telephone: (903) 223-3999
Fax No: (903) 223-8520
FRANKLIN R. HARRISON
Florida Bar No: 0142350
Email:fharrison@harrisonsale.com
Harrison, Sale, McCloy, Chartered
304 Magnolia Avenue
Panama City, Florida 32401-3125
Telephone: (850) 769-3434
ADRIEN A. (“BO”) RIVARD, III
Florida Bar No: 0105211
Email: brivard@harrisonrivard.com
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40. Case 5:13-cv-00123-RS-GRJ Document 1 Filed 04/20/13 Page 40 of 40
Harrison Rivard Duncan & Buzzett, Chtd.
101 Harrison Avenue
Panama City, Florida 32401
Telephone: (850) 769-7714
Counsel for Plaintiff, State of Florida
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PAMELA JO BONDI
ATTORNEY GENERAL
STATE OF FLORIDA
BY: s/ Russell S. Kent
RUSSELL S. KENT
Special Counsel for Litigation
Florida Bar No. 0020257
E-Mail: russell.kent@myfloridalegal.com
Office of the Attorney General
The Capitol, PL-01
Tallahassee, FL 32399-1050
Telephone: (850) 414-3854
PATRICIA A. CONNERS
Associate Deputy Attorney General
Florida Bar No. 361275
Email: Trish.Conners@myfloridalegal.com
Office of the Attorney General
The Capitol, PL-01
Tallahassee, FL 32399-1050
Telephone: (850) 245-0140
-and-
CARL R. NELSON
Florida Bar No: 0280186
Email: cnelson@fowlerwhite.com
FOWLER WHITE BOGGS P.A.
P.O. Box 1438
Tampa, FL 33601-1438
Telephone: (813) 228-7411
S. DRAKE MARTIN
Florida Bar No: 0090479
Email: drakemartin@nixlawfirm.com
Nix Patterson & Roach, LLP
1701 E. County Hwy 30-A, Suite 201-B
Santa Rosa Beach, FL 32459
Telephone: (850) 231-4028
43. Case 5:13-cv-00123-RS-GRJ Document 1-1 Filed 04/20/13 Page 3 of 3
LOUIS B. (“BRADY”) PADDOCK
Texas Bar No: 00791394
Arkansas Bar No: 93135
Louisiana Bar No. 28711
Email: bpaddock@nixlawfirm.com
Nix, Patterson & Roach, LLP
2900 St. Michael Drive, Suite 500
Texarkana, TX 75503-5211
Telephone: (903) 223-3999
Fax No: (903) 223-8520
FRANKLIN R. HARRISON
Florida Bar No: 0142350
Email:fharrison@harrisonsale.com
Harrison, Sale, McCloy, Chartered
304 Magnolia Avenue
Panama City, Florida 32401-3125
Telephone: (850) 769-3434
ADRIEN A. (“BO”) RIVARD, III
Florida Bar No: 0105211
Email: brivard@harrisonrivard.com
Harrison Rivard Duncan & Buzzett, Chtd.
101 Harrison Avenue
Panama City, Florida 32401
Telephone: (850) 769-7714
Counsel for Plaintiff, State of Florida
44. Case 5:13-cv-00123-RS-GRJ Document 1-2 Filed 04/20/13 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
Northern District of Florida
__________ District of __________
State of Florida )
)
)
)
Plaintiff(s) )
)
v. Civil Action No.
)
BP Exploration & Production, Inc., BP p.l.c., BP )
America Production Company, and Halliburton )
Energy Services, Inc.
)
)
Defendant(s) )
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
BP America Production Company
c/o CT Corporation System
1200 South Pine Island Road
Plantation, Florida 33324
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
Russell S. Kent
Office of the Attorney General
State of Florida
The Capitol, PL-01
Tallahassee, Florida 32399-1050
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
45. Case 5:13-cv-00123-RS-GRJ Document 1-2 Filed 04/20/13 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at (place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Print Save As... Reset
46. Case 5:13-cv-00123-RS-GRJ Document 1-3 Filed 04/20/13 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
Northern District of Florida
__________ District of __________
State of Florida )
)
)
)
Plaintiff(s) )
)
v. Civil Action No.
)
BP Exploration & Production, Inc., BP p.l.c., BP )
America Production Company, and Halliburton )
Energy Services, Inc.
)
)
Defendant(s) )
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
BP p.l.c.
International Headquarters
1 St. James Square
London, SW1Y 4PD UK
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
Russell S. Kent
Office of the Attorney General
State of Florida
The Capitol, PL-01
Tallahassee, Florida 32399-1050
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
47. Case 5:13-cv-00123-RS-GRJ Document 1-3 Filed 04/20/13 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at (place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Print Save As... Reset
48. Case 5:13-cv-00123-RS-GRJ Document 1-4 Filed 04/20/13 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
Northern District of Florida
__________ District of __________
State of Florida )
)
)
)
Plaintiff(s) )
)
v. Civil Action No.
)
BP Exploration & Production, Inc., BP p.l.c., BP )
America Production Company, and Halliburton )
Energy Services, Inc.
)
)
Defendant(s) )
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
BP Exploration & Production, Inc.
c/o CT Corporation System
1200 South Pine Island Road
Plantation, Florida 33324
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
Russell S. Kent
Office of the Attorney General
State of Florida
The Capitol, PL-01
Tallahassee, Florida 32399-1050
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
49. Case 5:13-cv-00123-RS-GRJ Document 1-4 Filed 04/20/13 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at (place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Print Save As... Reset
50. Case 5:13-cv-00123-RS-GRJ Document 1-5 Filed 04/20/13 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
Northern District of Florida
__________ District of __________
State of Florida )
)
)
)
Plaintiff(s) )
)
v. Civil Action No.
)
BP Exploration & Production, Inc., BP p.l.c., BP )
America Production Company, and Halliburton )
Energy Services, Inc.
)
)
Defendant(s) )
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
Halliburton Energy Services, Inc.
c/o CT Corporation System
1200 Plantation Road
Plantation, Florida 33324
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
Russell S. Kent
Office of the Attorney General
State of Florida
The Capitol, PL-01
Tallahassee, Florida 32399-1050
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
51. Case 5:13-cv-00123-RS-GRJ Document 1-5 Filed 04/20/13 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at (place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Print Save As... Reset