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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

PENSACOLA DIVISION 

IN THE MATTER OF IN RE 

SKANSKA USA CIVIL 

SOUTHEAST INC. AND 

SKANSKA USA, INC. AS 

OWNERS OF THE BARGE KS 

5531 PRAYING FOR 

EXONERATION FROM OR 

LIMITATION OF LIABILITY 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§

ADMIRALTY RULE 9(H) 

 § 

§

CIVIL ACTION NO. 

3:20-CV-05980-LC/HTC

ORDER TO SHOW CAUSE 

This matter is before the Court on two (2) issues raised during the July 21, 

2021, weekly discovery conference, which are discussed further below. The first is 

the United States’ opposition to Skanska’s request and notice of depositions of Navy 

witnesses and the second is the Claimant’s oral motion for sanctions relating to 

allegedly missing cell phone data. 

I. DEPOSITIONS OF UNITED STATES NAVY WITNESSES 

On July 20, 2021, prior to the Court’s regularly scheduled discovery 

conference, counsel for the United States advised the Court that it had received a 

request from Skanska for fifteen (15) witnesses who are under the control of the 

Navy. See July 19, 2021, R. Hyde letter (attached). The United States advised 

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Case No. 3:20-cv-05980-LC-HTC 

Skanska that it objected to these depositions and any areas of inquiry which would 

contravene the Court’s Discovery Order #2 (ECF Doc. 1192), regarding the 

relevancy of the conduct taken by the Navy in preparation for Hurricane Sally. Id. 

The United States, however, was willing to make available two (2) Navy witnesses 

and three (3) United States Coast Guard witnesses, to testify about matters not 

addressed in Discovery Order #2 (ECF Doc. 1192). 

In response, Skanska’s counsel asked for an opportunity to “preserve a record,” 

and sought for the Court to order the United States to file a “formal motion to quash 

the subpoenas or a motion for protective order.” See S. Remington email (attached). 

At the time of Mr. Remington’s email, however, no subpoenas had been issued. 

Regardless, since that time, Skanska has served notices of deposition on the United 

States for the disputed witnesses. 

At the discovery conference held on July 21, 2021, the United States raised 

this issue once again, but because lead counsel on this matter for Skanska was not in 

attendance, did not address the merits of the dispute other than that the United States 

feels the depositions are contrary to the Court’s prior ruling. Also, the morning of 

the status conference, Skanska’s counsel sent a letter to the Court, stating that “it is 

entitled to depose the Navy’s witnesses regarding their evaluation of whether and to 

what extent Hurricane Sally would impact Pensacola.” See July 21, 2021, D. Walker 

letter (attached). 

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Case No. 3:20-cv-05980-LC-HTC 

Given the upcoming trial date and the Court’s need to manage discovery in 

this case on an expedited basis, the Court accepts the United States’ letter and its 

statements on the record as an oral motion for protective order as well as a motion 

for compliance with the Court’s Discovery Order #2 (ECF Doc. 1192). Skanska is, 

thus, ordered to show cause why the depositions sought do not contravene either the 

letter or the spirit of the Court’s Discovery Order #2 (ECF Doc. 1192). 

The parties are also reminded, as the Court stated in open court, that pursuant 

to the Federal Rules, the Court shall, after an opportunity to be heard, require the 

losing party, counsel, or both to pay the winning party’s reasonable expenses, 

including attorneys’ fees, unless the motion or opposition was substantially justified. 

Fed. R. Civ. P. 37(a)(5)(A), (B). 

II. CLAIMANT’S ORAL MOTION TO SHOW CAUSE AND FOR 

SANCTIONS 

At the weekly discovery conference, Claimants raised an issue relating, to what 

they believe was Skanska’s lack of candor with the Court with regard to certain cell 

phone data. According to Skanska, some of the custodians’ cell phones are no longer 

available or the data is no longer available because the cell phones were either 

“wiped” upon the custodian’s termination, went overboard, or the custodian deleted 

text messages from the phone. While Skanska has taken the position that text 

messages for these custodians were produced from other custodian cell phones, based 

on Claimants’ calculations, those numbers are minimal. Specifically, other than 

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Case No. 3:20-cv-05980-LC-HTC 

McGlynn and Rubio, for which over 300 text messages were produced from other 

custodian cell phones, just over 20 messages were produced for the other four (4) 

custodians. 

Additionally, Claimants argue Skanska misrepresented to the Court that one 

of those custodians, Rob Hill, a tug boat operator, did not have a cell phone. To the 

contrary, Claimants argue they have identified a cell phone for Hill in the Skanska’s 

Hurricane Preparedness Plan and also found at least one message sent from Hill on a 

cell phone. Claimants, thus, seek an order to show cause against Skanska, including 

seeking as relief, that Skanska produce cell phone data for five (5) additional 

custodians and provide Hill’s phone. 

While the Claimants have previously made known their concern over missing 

data, because Claimants’ findings were not previously provided to Skanska, the Court 

will afford Skanska an opportunity to meet and confer with Claimants and to submit 

a written response to Claimants’ oral motion. 

Accordingly, it is ORDERED: 

1. Skanska shall show cause why a protective order should not be issued 

and why the depositions at issue do not contravene the Court’s Discovery Order #2 

(ECF Doc. 1192) by submitting a written response to the United States’ letter and 

oral motion. The response shall be filed by close of business Monday, July 26, 2021. 

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Case No. 3:20-cv-05980-LC-HTC 

In its response, Skanska shall also address why fifteen (15) Navy witnesses are 

necessary. 

2. The United States may file a reply to Skanska’s response by close of 

business, Tuesday, July 27, 2021. 

3. Skanska and Claimants are directed to meet and confer prior to Monday 

July 26, 2021, and if the Claimants’ motion has been resolved, Claimants shall notify 

the Court of same. If the motion has not been resolved, Skanska shall, by close of 

business Monday, July 26, 2021, file a written response to the Claimants’ oral 

motion to show cause and for sanctions. 

4. Claimants may file a reply to Skanska’s response to their motion, also 

by close of business, Tuesday, July 27, 2021. 

5. The parties shall be ready to address both motions at the Wednesday, 

July 28, 2021, status conference. 

DONE and ORDERED this 21st day of July 2021. 

 /s/ Hope Thai Cannon 

 HOPE THAI CANNON 

 UNITED STATES MAGISTRATE JUDGE

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14, 2021 request), Chief Warrant Officer Brandon Burke, and Lieutenant Allison Denning. On 

July 16, 2021, you sent a formal request to Rob Kelly requesting to depose CAPT Landon Allen, 

LT Allison Denning, LT Megan Falco, and Chief Warrant Officer Brandon Burke. You further 

added Mr. Keith Raisch and Ms. Kimberly Tessier to your list of United States Navy witnesses 

you wish to depose.

In total, Skanska has requested the depositions of 15 Navy and Coast Guard personnel. As 

this is the liability phase of the trial, we assume that Skanska intends to uses these deponents to 

prove it has no liability for the Skanska barge that the Navy had to remove from its property and 

the barge that struck the Navy’s bridge.

I understand and agree with your July 14 assertion that we do not want the United States 

or Skanska to be criticized for holding up necessary depositions. To that end, please consider this 

letter as an effort to reduce the workload of all parties. 

Considering Judge Collier’s July 14, 2021, ruling regarding the relevancy of certain

Skanska written discovery, the United States believes that several witnesses requested are

irrelevant to the liability issues. Similarly, none of the above witnesses could contribute to laying 

the groundwork for any liability expert opinion. Specifically, Navy witnesses that could testify 

about actions taken or not taken by Naval Air Station Pensacola (“NASP”) to prepare for the storm 

are not relevant. As stated in the order, “Skanska’s attempt to use what the United States Navy 

knew or did during Hurricane Sally to establish the reasonableness of its actions fares no better. 

The Navy did not own any barges and the Navy did not have any barges located near the Pensacola 

Bay Bridge.” See Dkt. 1192 at 5.

Addressing the requested witnesses, Captain Kinsella, as Commanding Officer of NASP, 

is not familiar with barge operations and has not worked with construction barges. Any questions 

directed to him regarding the preparations of NASP for the hurricane or what the Navy “knew or 

did” would be impermissible. He only has second hand supervisory-type knowledge of the damage 

caused by the barges and damages are not in issue at this stage of the trial. The United States fears

that Skanska may still be attempting to initiate discovery regarding the hurricane preparations of 

NASP in order to prove the reasonableness of Skanska’s actions or Skanska’s knowledge of the 

weather. 

Mr. Burt Fenters is the retired former Emergency Operations Center Director for NASP. 

He does have familiarity with Navy weather preparations before the storm but that raises the same 

problem. 

MA3 Russ Aguda, MA1 Anthony Vasquez, and LCDR Stephen Pakula are percipient 

witnesses that can attest to Skanska barges striking areas of NAS Pensacola. However, 

photographic and video evidence provided by these same individuals would relegate their 

depositions to mere authentication formalities. Given the shortness of time, we object to spending 

effort now on these depositions. If you choose, we can work with you to create a stipulation as to 

what each person saw and when and how they took the photographic and video evidence you have 

received.

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Mr. Brandon Davis can speak to Navy damages, which as described above are not

important for this phase of the trial. He was not an eyewitnesses to the events and has no

information with regard to securing vessels in preparation for inclement weather. 

Mr. Keith Raisch and Ms. Kimberly Tessier are both employees of NASP’s Morale, 

Welfare, and Recreation (MWR) Marinas. Both would be able to speak to Marina preparations 

for the storm and damages to NASP from Hurricane Sally. Again, Judge Cannon has declared 

NASP’s preparations for the hurricane beyond the scope of current discovery. 

Mr. John Baxter, Ms. Sarah Murtaugh, and Ms. Sue Brink can speak to the removal of 

Skanska’s barges from NASP and Navy Damages. While that may not be relevant to this phase 

of the trial, Mr. Baxter and Ms. Murtagh spoke to Skanska’s employee, Mr. Mason Ford, during 

the recovery of Skanska’s two barges from NASP. In these conversations, Mr. Ford stated to Mr. 

Baxter and Ms. Murtagh that Skanska or Skanska’s insurance company would reimburse the U.S. 

Government for the costs associated with recovering Skanska’s barges. In the interest of time, we 

are willing to agree to limited stipulations of Mr. Baxter and Ms. Murtagh’s testimony on their 

conversation with Mr. Ford. In the alternative, we will agree to limited depositions on the same 

topic. After the phase I trial, we agree to make Mr. Baxter and Ms. Murtagh available for full 

depositions covering damages.

Additionally you have indicated that there are four members of the United States Coast 

Guard that you wish to depose. We are we in the process of getting deposition dates for these 

personnel. Apparently, you have also tried to contact the Coast Guard. We have been informed 

that Tom Forbes of your office has been personally attempting to contact Coast Guard personnel 

to schedule depositions. Please desist. Before your attempted improper contact with government 

witnesses our office had already asked the Coast Guard Office of Maritime Litigation to relax the 

Touhy requirements in order to expedite production of Coast Guard witnesses. The Coast Guard 

has agreed and you need to merely work with DOJ to procure relevant witnesses for litigation. I 

ask that you refrain from contacting any further United States government agency or employer to 

produce witness unless you do so through Rob Kelly or myself. I will get you deposition dates for 

these Coast Guard personnel as soon as possible, but as Rob Kelly is out of the office on family 

business through July 26, 2021, we cannot begin double tracking deposition until after that date. 

As to the Coast Guard personnel, the United States objects to only LT Megan Falco. LT 

Falco was a Marine Casualty Investigator who collected information post-Sally. She has no 

specific knowledge of Skanska barges pre-Sally. She has no direct experience with barges. Her 

only connection here is that she was a collection point for information/investigation materials after 

the storm. She did not personally see any of Skanska barges after the storm. 

In summary, the United States objects to the production of the following Navy witnesses:

1. CAPT Timothy Kinsella, USN;

2. Mr. Burt Fenters, (USN civilian);

3. MA3 Russ Aguda, USN;

4. MA1 Anthony Vasquez, USN;

5. LCDR Stephen Pakola, USN; 

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6. Mr. Brandon Davis (USN civilian);

7. Mr. John Baxter (USN civilian);

8. Ms. Sarah Murtagh (USN civilian);

9. Ms. Sue Brink (USN civilian);

10. Mr. Keith Raisch (USN civilian);

11. Kimberly Tessier (USN civilian), and

12. LT Megan Falco (USCG).

If questioning is limited by the scope of Magistrate Judge Cannon’s relevancy rulings we 

are willing to waive our objection and produce for limited testimony, the following Navy witnesses

after July 26, 2021;

1. Mr. John Baxter (USN civilian) and

2. Ms. Sarah Murtagh (USN civilian),

The following United States Coast Guard witnesses are available for deposition beginning 

July 27, 2021:

3. CAPT LaDonn Allen (again, we assume this is the “CAPT Landon Allen” of your 

July 14, 2021 request)

4. Chief Warrant Officer Brandon Burke, 

5. Lieutenant Allison Denning.

As stated above, we are working to obtain the earliest available deposition dates for all five 

personnel. I hope we can agree that your other requested depositions are not appropriate or 

necessary in the current litigation posture. 

/s/ Robb Hyde

Robb Hyde

Trial Attorney

Case 3:20-cv-05980-LC-HTC Document 1210 Filed 07/21/21 Page 9 of 16
From: Scott Remington

To: Hope Cannon; Hyde, Robb (CIV)

Cc: Ashley Ross; Sam Geisler; Stephen Echsner; Brian Barr (External); Thomas Gonzalez (External); Kelly, Robert

(CIV); Blanchard, Charles; Walker, Derek; Elizabeth C. Billhimer; Jeremy Branning; Christine Bracken Moore;

Nikki Guntner; Flynn, Stephen (CIV); SkanskaLitGroup (External); "Watson, Harold"

Subject: RE: In re Skanska 3:20-CV-05980-LC-HTC - Letter re Skanska"s Privilege Log Prod 006

Date: Tuesday, July 20, 2021 2:41:17 PM

Attachments: Facebook 55598884-7995-4d93-92d3-5101d580d70c.png

LinkedIn 57c89113-2875-479d-9fdd-fd3a2a809f98.png

Twitter 216c94ca-a91c-458c-ad76-295500e4747c.png

Instagram c437b822-13ce-4d58-87bc-212014b134fa.png

CAUTION - EXTERNAL: 

Judge Cannon,

In order to preserve a record on this issue we would request the U.S. Navy-- at its discretion file a

formal motion to quash the subpoenas or a motion for a protective order. This issue is not one we

believe can be handled informally.

Once this is done, we can respond in writing ensure our record is clear, clean, and correct before we

come before the court. If the Navy’s motion and our response can be expedited, Skanska can make

itself available between 1:00 and 3:00 next Monday.

Respectfully submitted

Scott Remington

Scott Remington | Shareholder - President

sremington@clarkpartington.com | (850) 432-2399

CLARK PARTINGTON

Office: (850) 434-9200 | Fax: (850) 432-7340 

125 East Intendencia Street, 4th Floor

Pensacola, Florida 32502 

clarkpartington.com

From: Hope Cannon <Hope_Cannon@flnd.uscourts.gov> 

Sent: Tuesday, July 20, 2021 2:37 PM

To: Hyde, Robb (CIV) <Robb.Hyde@usdoj.gov>

Cc: Ashley Ross <Ashley_Ross@flnd.uscourts.gov>; Sam Geisler <SGeisler@awkolaw.com>; Stephen

Echsner <SEchsner@awkolaw.com>; Brian Barr (External) <bbarr@levinlaw.com>; Thomas Gonzalez

(External) <TFG@beggslane.com>; Kelly, Robert (CIV) <Robert.Kelly@usdoj.gov>; Blanchard, Charles

<Blanchard@chaffe.com>; Scott Remington <sremington@clarkpartington.com>; Walker, Derek

Case 3:20-cv-05980-LC-HTC Document 1210 Filed 07/21/21 Page 10 of 16
<WalkerD@chaffe.com>; Elizabeth C. Billhimer <ebillhimer@clarkpartington.com>; Jeremy Branning

<jbranning@clarkpartington.com>; Christine Bracken Moore <cbmoore@clarkpartington.com>;

Nikki Guntner <NGuntner@awkolaw.com>; Flynn, Stephen (CIV) <Stephen.Flynn@usdoj.gov>;

SkanskaLitGroup (External) <SkanskaLitGroup@awkolaw.com>

Subject: Re: In re Skanska 3:20-CV-05980-LC-HTC - Letter re Skanska's Privilege Log Prod 006

Mr. Hyde - I am not available on Friday, but we can do the hearing on Thursday at 10 cst. We can

also hold the hearing on Monday as well, anytime between 1-3. Please coordinate with other

counsel and email chambers with the agreed upon date/time.

Thanks.

Hope Thai Cannon

Magistrate Judge

United States District Court Northern District of Florida

On Jul 20, 2021, at 2:00 PM, Hyde, Robb (CIV) <Robb.Hyde@usdoj.gov> wrote:

CAUTION - EXTERNAL:

Dear Judge Cannon,

Attached is a letter the United States sent to Skanska attorney Derek Walker this

morning objecting to the depositions of various Navy personnel. We intended to

bring this issue before you tomorrow but Skanska’s lead attorneys will be

traveling and it would not be fair to them. We understand that you intended

tomorrow to be the last discovery hearing and apologize for the inconvenience to

the Court. We request a special discovery session before you later in the week if

possible. The United States can make itself available for any time or date later

this week.

Very Respectfully,

Robb Hyde

Trial Attorney

United States Department of Justice

Civil Division, Torts Branch

Aviation, Space and Admiralty Litigation

175 N St. NE

Washington, DC 20002

P.O. Box 14271

Washington, DC 20044-4271

Case 3:20-cv-05980-LC-HTC Document 1210 Filed 07/21/21 Page 11 of 16
(202) 616-4106

Cell: (301) 537-0640

robb.hyde@usdoj.gov

From: Nikki Guntner <NGuntner@awkolaw.com> 

Sent: Monday, July 19, 2021 9:42 AM

To: 'Hope Cannon' <Hope Cannon@flnd.uscourts.gov>; Ashley Ross

<Ashley Ross@flnd.uscourts.gov>

Cc: Sam Geisler <SGeisler@awkolaw.com>; Stephen Echsner

<SEchsner@awkolaw.com>; Brian Barr (External) <bbarr@levinlaw.com>; Thomas

Gonzalez (External) <tfg@beggslane.com>; Kelly, Robert (CIV)

<Robert.Kelly@usdoj.gov>; Hyde, Robb (CIV) <Robb.Hyde@usdoj.gov>; Blanchard,

Charles <Blanchard@chaffe.com>; Scott Remington

<sremington@clarkpartington.com>; Walker, Derek <WalkerD@chaffe.com>; Elizabeth

C. Billhimer <ebillhimer@clarkpartington.com>; Jeremy Branning

<jbranning@clarkpartington.com>; Christine Bracken Moore

<cbmoore@clarkpartington.com>

Subject: In re Skanska 3:20-CV-05980-LC-HTC - Letter re Skanska's Privilege Log Prod

006

Dear Judge Cannon,

Attached please find a letter and corresponding spreadsheet regarding Skanska’s

privilege log for Production 006.

Thank you,

Nikki Guntner

D. Nicole Guntner

Aylstock, Witkin, Kreis & Overholtz PLLC

17 East Main Street, Suite 200

Pensacola, Florida 32502

Phone: (850) 202-1010

Fax: (850) 916-7449

https://link.edgepilot.com/s/5ca5f49a/7tdJHBxBkU_xfl6kFg9osQ?u=http://www.awkolaw.com/

This electronic message and/or its attachments contain legally privileged and

confidential information intended only for the use of the addressee. If the reader

of this message is not the intended recipient, you are hereby notified that any

reading, dissemination, disclosure, distribution, or copying of this transmission or

Case 3:20-cv-05980-LC-HTC Document 1210 Filed 07/21/21 Page 12 of 16
its attachments is strictly prohibited. If you receive this communication in error,

please immediately notify the sender by electronic mail, and delete this message,

its attachments and all copies and backups.

CAUTION - EXTERNAL EMAIL: This email originated outside the

Judiciary. Exercise caution when opening attachments or clicking on links.

<Objection to Navy Witnesses - Final.pdf>

CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution

when opening attachments or clicking on links.

Case 3:20-cv-05980-LC-HTC Document 1210 Filed 07/21/21 Page 13 of 16
 HAROLD K. WATSON

 Partner 

Licensed in Texas and Louisiana

Direct Dial No: (713) 343-2952 

Direct Fax No: (713) 546-9806 

E-mail: watson@chaffe.com

New Orleans: 2300 Energy Centre • 1100 Poydras Street • New Orleans, LA 70163-2300 • Tel: (504) 585-7000 • Fax: (504) 585-7075 

Baton Rouge: 103 Two United Plaza • 8550 United Plaza Blvd. • Baton Rouge, LA 70809 • Tel: (225) 922-4300 • Fax: (225) 922-4304 

Houston: 801 Travis Street, Suite 1910 • Houston, TX 77002 • Tel: (713) 546-9800 • Fax: (713) 546-9806 

Lake Charles: One Lakeshore Drive, Suite 1640A • Lake Charles, LA 70629 • Tel: (337) 419-1825 Fax: (504) 585-7075 

www.chaffe.com 

3379011-1

July 21, 2021

Via email: Hope Cannon@flnd.uscourts.gov 

Hope Thai Cannon 

United States Magistrate Judge 

Northern District of Florida 

One North Palafox St. 

Pensacola, FL 32502 

 Re: In Re: Skanska USA Civil Southeast, Inc. et al 

 USDC FLND C. A. No. 3:20-CV-05980-MW-MJF 

Dear Judge Cannon: 

 We have been discussing the depositions of DOJ controlled witnesses for nearly two 

weeks with Messrs. Hyde and Kelly. Once discovery responses identified additional witnesses 

who may have relevant information to Skanska’s defense, we promptly requested their 

depositions and then noticed them. We were informed today that the DOJ has made the unilateral 

determination that the witnesses do not have relevant information and will apparently not be 

produced for their depositions. 

 Skanska believes that the question of whether it is entitled to depose the Navy’s witnesses 

regarding their evaluation of whether and to what extent Hurricane Sally would impact 

Pensacola is a matter that needs to be handled formally so as to preserve the record. We believe 

that if the DOJ objects to these depositions, they should file a motion for a protective order 

setting forth the reasons they do not believe these depositions should go forward, thus giving 

Skanska the opportunity to file a formal response. We have requested the DOJ to do this, but 

they have refused to do so. 

 You had suggested this matter be addressed at a hearing on Monday, July 26 between 

1:00 and 3:00. In keeping with this proposed schedule, we would ask that the DOJ be ordered to 

file a motion for a protective order by Thursday, July 22, with Skanska’s response due at your 

opening on Monday, July 26. We are of course willing to work with the Court and opposing 

counsel if these dates and times are inconvenient. 

Case 3:20-cv-05980-LC-HTC Document 1210 Filed 07/21/21 Page 14 of 16
July 21, 2021 

Page 2 of 3 

New Orleans: 2300 Energy Centre • 1100 Poydras Street • New Orleans, LA 70163-2300 • Tel: (504) 585-7000 • Fax: (504) 585-7075 

Baton Rouge: 103 Two United Plaza • 8550 United Plaza Blvd. • Baton Rouge, LA 70809 • Tel: (225) 922-4300 • Fax: (225) 922-4304 

Houston: 801 Travis Street, Suite 1910 • Houston, TX 77002 • Tel: (713) 546-9800 • Fax: (713) 546-9806 

Lake Charles: One Lakeshore Drive, Suite 1640A • Lake Charles, LA 70629 • Tel: (337) 419-1825 Fax: (504) 585-7075 

www.chaffe.com 

3379011-1

Respectfully submitted: 

 /s/ Derek A. Walker 

DEREK A. WALKER 

Admitted Pro Hac Vice 

KENNETH H. TRIBUCH 

Florida Bar No. 986887 

Harold. K. Watson, Esq. 

Charles P. Blanchard, Esq. 

Jon W. Wise, Esq. 

CHAFFE MCCALL, LLP 

801 Travis, Suite 1910 

Houston, Texas 77002 

Telephone: (713) 546-9800 

Facsimile: (713) 546-9806 

And 

SCOTT A. REMINGTON 

Florida Bar No. 122483 

JEREMY C. BRANNING 

Florida Bar No. 507016 

CLARK PARTINGTON 

P.O. Box 13010 

Pensacola, FL 32591-3010 

Telephone: (850) 434-9200 

Facsimile: (850) 432-7340 

Attorneys for Skanska USA Civil Southeast Inc. 

and Skanska USA, Inc. 

cc: 

VIA EMAIL ONLY: 

Robb.Hyde@usdoj.gov

Robert.Kelly@usdoj.gov

Robb Hyde 

Robert Kelly 

VIA EMAIL ONLY: 

baylstock@awkolaw.com

sgeisler@awkolaw.com

sallyteam@awkolaw.com

Case 3:20-cv-05980-LC-HTC Document 1210 Filed 07/21/21 Page 15 of 16
July 21, 2021 

Page 3 of 3 

New Orleans: 2300 Energy Centre • 1100 Poydras Street • New Orleans, LA 70163-2300 • Tel: (504) 585-7000 • Fax: (504) 585-7075 

Baton Rouge: 103 Two United Plaza • 8550 United Plaza Blvd. • Baton Rouge, LA 70809 • Tel: (225) 922-4300 • Fax: (225) 922-4304 

Houston: 801 Travis Street, Suite 1910 • Houston, TX 77002 • Tel: (713) 546-9800 • Fax: (713) 546-9806 

Lake Charles: One Lakeshore Drive, Suite 1640A • Lake Charles, LA 70629 • Tel: (337) 419-1825 Fax: (504) 585-7075 

www.chaffe.com 

3379011-1

Bryan F. Aylstock 

E. Samuel Geisler 

Aylstock, Witkin, Kreis & Overholtz, PLLC 

17 East Main Street 

Second Floor 

Pensacola, Florida 32502 

 

VIA EMAIL ONLY: 

tfg@beggslane.com

jnd@beggslane.com

Thomas F. Gonzalez 

J. Nixon Daniel, III 

Beggs & Lane, RLLP 

501 Commendencia Street 

Pensacola, Florida 32502 

VIA EMAIL ONLY: 

bbarr@levinlaw.com

epaulos@levinlaw.com

Brian H. Barr 

Emmanuella J. Paulos 

Levin Papantonio Rafferty Proctor Buchanan O'Brien Barr & Mougey, P.A. 

316 S. Baylen Street 

Suite 600 

Pensacola, Florida 32502 

Case 3:20-cv-05980-LC-HTC Document 1210 Filed 07/21/21 Page 16 of 16