UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

SCOTT CARSWELL, JULIE CARSWELL,

KENT McCOY, JANINE McCOY, and ROBERT

HOWARD, individually and as representatives of

similarly situated persons,

Plaintiffs,

CASE NO.:4:10-cv-00486- SPM-WCS

vs.

LISA ECHEVERRI, as Executive Director of the

Florida Department of Revenue, acting in her

official capacity, and BP, plc; BP PRODUCTS

NORTH AMERICA, INC.; BP AMERICA,

INC.; BP EXPLORATION AND

PRODUCTION, INC.; BP AMERICAN

PRODUCTION COMPANY; TRANSOCEAN,

LTD; TRANSOCEAN OFFSHORE

DEEPWATER DRILLING, INC.;

TRANSOCEAN DEEPWATER,

INC.;TRANSOCEAN HOLDINGS, LLC;

TRITON ASSET LEASING GMBH;

HALLIBURTON ENERGY SERVICES, INC.;

CAMERON INTERNATIONAL

CORPORATION f/k/a COOPER CAMERON

CORPORATION; ANDARKO PETROLEUM

CORPORATION; ANDARKO E&P

COMPANY, L.P.; MOEX OFFSHORE 2007,

LLC; M-I, LLC; DRIL-QUIP, INC.; MITSUI

OIL EXPLORATION; and HYUNDAI HEAVY

INDUSTRIES CO., LTD., INC.,

Defendants.

Defendant Florida Department of Revenue’s 

Notice of Amendment to N.D. Fla. Loc. R. 7.1(B) Conference 

Defendant Lisa Echeverri, as Executive Director of the Florida Department of Revenue, 

acting in her official capacity (hereinafter “the Florida Department of Revenue”), by and through 

her undersigned counsel, hereby files this Notice of Amendment to Northern District of Florida 

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Local Rule 7.1(B) Conference as filed in the Florida Department of Revenue’s Motion to 

Expedite the Consideration of the Defendant Florida Department of Revenue’s Motion to 

Dismiss and in the Alternative Remand (Florida Department of Revenue’s Motion to Expedite)

(Dkt # 27). 

The Florida Department of Revenue reports the following as Halliburton Energy 

Services, Inc.'s position on the relief sought by the Florida Department of Revenue in both the 

Florida Department of Revenue’s Motion to Expedite and in the Florida Department of 

Revenue’s Motion to Dismiss and in the Alternative Remand (Dkt # 26):

AMENDED CONFERENCE PURSUANT TO N.D. FLA. LOC. R. 7.1(B)

Counsel for the Florida Department of Revenue has further conferred with counsel for 

Halliburton Energy Services, Inc. ("HESI") regarding the Florida Department of Revenue’s 

Motion to Dismiss and in the Alternative Remand, as well as the Florida Department of 

Revenue’s Motion to Expedite. Counsel for HESI has advised counsel for the Florida 

Department of Revenue and further authorized counsel for the Florida Department of Revenue to 

state the following as its position with respect to both the Florida Department of Revenue’s 

Motion to Expedite and Motion to Dismiss and in the Alternative Remand:

Counsel for HESI has advised counsel for the Department that, 

while it may not agree with every ground for dismissal as stated in 

the Department's Motion, HESI does not oppose the dismissal of 

this case as requested in the Department's Motion. Specifically, 

HESI agrees that dismissal is appropriate under Article III of the 

Constitution for lack of a justiciable controversy and plaintiffs' 

lack of standing, as well as the Tax Injunction Act and the 

Eleventh Amendment. HESI has advised that its non-opposition to 

the dismissal of this case as sought in the Department's Motion is 

not intended to waive HESI's support of the transfer and 

consolidation of this case pursuant to Conditional Transfer Order 

No. 6 of the Judicial Panel on Multidistrict Litigation, filed in 

MDL No. 2179 on November 10, 2010, nor is it intended to waive 

HESI's request for stay pending the determination of such transfer, 

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as requested by HESI in D.E. 17. HESI opposes remand of this 

case to state court.

Respectfully submitted,

BILL McCOLLUM 

ATTORNEY GENERAL

/s/ Jonathan A. Glogau________

Jonathan A. Glogau

Chief, Complex Litigation

Fla. Bar No. 371823

PL-01, The Capitol

Tallahassee, FL 32399-1050

850-414-3300, ext. 4817

850-414-9650 (fax)

jon.glogau@myfloridalegal.com

Joseph C. Mellichamp, III

Chief, Revenue Litigation Bureau

Florida Bar No. 133249

Office of the Attorney General 

The Capitol, 

PL-01 Tallahassee, FL 32399-1050 

(850) 414-3300

(850) 410-2672 (fax)

Joe.Mellichamp@myfloridalegal.com

Counsel for Defendant Lisa Echeverri

CERTIFICATE OF SERVICE

I hereby certify that on December 6, 2010, the foregoing document was filed with the 

Clerk of Court via the CM/ECF system, causing it to be served on all counsel of record.

/s/ Jonathan A. Glogau

 Attorney

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