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UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF FLORIDA 

TALLAHASSEE DIVISION 

Case No. 4:10-cv-00486-SPM-WCS 

SCOTT CARSWELL, JULIE CARSWELL, 

KENT McCOY, JANINE McCOY, and 

ROBERT HOWARD, individually and as 

representatives of similarly situated persons, 

Plaintiffs, 

v. 

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 HOLDINGS, LLC; 

TRITON ASSET LEASING GMBH; 

HALLIBURTON ENERGY SERVICES, 

INC.; CAMERON INTERNATIONAL 

CORPORATION f/k/a COOPER 

CAMERON CORPORATION; 

ANADARKO PETROLEUM 

CORPORATION; ANADARKO E & p 

COMPANY, L.P.; MOEX OFFSHORE 

2007, L.L.C.; M-I, LLC; DRIL-QUIP, INC.; 

MITSUI OIL EXPLORATION; and 

HYUNDAI HEAVY INDUSTRIES CO. 

LTD., INC., 

Defendants. 

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HALLIBURTON ENERGY SERVICES, INC.’S

UNOPPOSED MOTION FOR EXTENSION OF TIME

Case 4:10-cv-00486-SPM -WCS Document 22 Filed 11/23/10 Page 1 of 6
 Defendant Halliburton Energy Services, Inc. ("HESI"), files this unopposed request for 

an order extending the time for HESI to file a responsive pleading to Plaintiffs' Amended 

Complaint and, as good cause, states: 1

1. This case is one of more than 300 related cases filed against HESI in various state 

and federal courts in the Southeastern United States arising out of an April 20, 2010, explosion 

and fire onboard Defendant Transocean’s Deepwater Horizon Drilling Rig and the ensuing oil 

spill from a British Petroleum well located on Mississippi Canyon Block 252 (“Deepwater 

Horizon Incident”). 

2. As a result of the Deepwater Horizon Incident, numerous plaintiffs have filed 

individual and class action lawsuits alleging injuries to their person, injuries related to their 

business or commercial interests, and/or injuries to their real or personal property. These 

lawsuits were filed across jurisdictions in at least six different states in the Southeastern United 

States. 

3. Pursuant to 28 U.S.C. §1407, many of the involved parties filed motions to 

consolidate the cases relating to the Deepwater Horizon Incident before the Judicial Panel on 

Multidistrict Litigation (“JPML”), in Case No. MDL 2179. After substantial briefing and oral 

argument, the JMPL ordered, on August 10, 2010, the consolidation of many then-existing 

lawsuits into multidistrict proceedings before the Honorable Carl Barbier in the Eastern District 

of Louisiana. Since that time, the JPML has entered multiple Conditional Transfer Orders, 

transferring numerous lawsuits not transferred with the original consolidation order. 

 

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In filing this extension request, HESI reserves all defenses—including its rights to object to jurisdiction, service of 

process, and any other issues in this matter—and all other defenses available pursuant to Federal Rule of Civil 

Procedure 12(b), including lack of subject matter jurisdiction, lack of personal jurisdiction, improper venue, 

insufficient process, insufficient service of process, failure to state a claim upon which relief can be granted, and 

failure to join necessary parties. Nevertheless, without waiving any rights, HESI files this extension request in the 

interests of judicial efficiency and economy.

Case 4:10-cv-00486-SPM -WCS Document 22 Filed 11/23/10 Page 2 of 6
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4. As indicated by the BP Defendants in their Motion to Stay (D.E. 16), the abovestyled action was identified as subject to consolidation and transfer into the MDL 2179 

proceedings, in Conditional Transfer Order No. 6. In response to the same, Plaintiffs have filed 

an objection to transfer with the JPML, for which a briefing schedule has been established (MDL 

2179, D.E. 349). If transferred, this case will be subject to consolidated pleadings and 

coordinated scheduling, and any answer by HESI in this action would be duplicative and a waste 

of resources. 

5. Prior to the filing of this Motion, HESI filed its Joinder with BP’s pending Motion 

to Stay these proceedings pending transfer by the Judicial Panel (D.E. 17). This Court has not 

yet ruled on BP’s Motion to Stay or HESI’s Joinder in the same. 

6. HESI’s responsive pleading to the Amended Complaint is currently due on, or 

before, December 6, 2010, which responsive pleading deadline may pass prior to the date the 

JPML resolves Plaintiffs’ pending objection to transfer. In the event this Court does enter a stay 

in this matter until after the JPML issues a ruling on the pending objection to transfer, HESI 

asserts that an extension of time to respond to the Amended Complaint for a minimum of twentyone (21) days after the date the JPML issues its ruling would be appropriate. Such relief is 

sought as part of HESI’s Joinder motion (D.E. 17). 

7. However, in the event this Court does not stay the proceedings as previously 

requested, HESI requests a thirty (30) day extension of time to file a responsive pleading to the 

Complaint, extending HESI’s deadline to respond to the Amended Complaint to January 5, 2010. 

8. As good cause shown for this request, the extension will assist with promoting 

efficiency and uniformity in all of the pending matters and will prevent a needless waste of time 

and resources by the parties and this court. 

Case 4:10-cv-00486-SPM -WCS Document 22 Filed 11/23/10 Page 3 of 6
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 WHEREFORE, HESI moves for an order granting this Motion for Extension of Time to 

file a responsive pleading until twenty-one (21) days after the date the JPML issues its ruling. 

Alternatively, HESI moves for an order granting it an additional thirty (30) days to file a 

responsive pleading. 

CERTIFICATE OF CONFERENCE PURSUANT TO N.D. FLA. L. R. 7.1(B)

 Prior to filing this Motion counsel for HESI conferred with counsel for the Plaintiffs in a 

good faith effort to resolve by agreement the issues raised herein. Counsel for the Plaintiffs has 

advised that Plaintiffs do not oppose the relief sought herein. 

Dated: November 23, 2010 

Case 4:10-cv-00486-SPM -WCS Document 22 Filed 11/23/10 Page 4 of 6
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GODWIN RONQUILLO PC 

By: /s/ Donald E. Godwin 

Donald E. Godwin

Attorney in Charge 

Texas Bar Number 08056500 

dgodwin@godwinronquillo.com 

Bruce W. Bowman, Jr.

Texas Bar Number 02752000 

bbowman@godwinronquillo.com 

Jenny L. Martinez 

Texas Bar Number 24013109 

jmartinez@godwinronquillo.com 

Gavin E. Hill 

Texas Bar Number 00796756 

ghill@godwinronquillo.com 

Floyd R. Hartley, Jr. 

Texas Bar Number 00798242 

fhartley@godwinronquillo.com 

1201 Elm Street, Suite 1700 

Dallas, Texas 75270-2041 

Telephone: 214.939.4400 

Facsimile: 214.760.7332 

and 

R. Alan York, 

Texas Bar Number 22167500 

ayork@godwinronquillo.com 

1331 Lamar, Suite 1665 

Houston, Texas 77010 

Telephone: 713.595.8300 

Facsimile: 713.425.7594 

BROAD AND CASSEL

By: /s/ Mark M. Barber 

Steven G. Burton 

Florida Bar Number 0793167 

sburton@broadandcassel.com 

Mark M. Barber 

Florida Bar Number 0573701 

mbarber@broadandcassel.com 

Regions Bank Building 

100 North Tampa Street, Suite 3500 

Tampa, Florida 33602 

Telephone: 813.225.3020 

Facsimile: 813.225.3039 

Ginger Lynne Barry 

Florida Bar Number 0294550 

gbarry@broadandcassel.com 

Regions Bank Building 

200 Grand Boulevard, Suite 205A 

Destin, Florida 32550 

Telephone: 850.269.0148 

Facsimile: 850.521.1472 

Counsel for Halliburton Energy Services, Inc. 

Case 4:10-cv-00486-SPM -WCS Document 22 Filed 11/23/10 Page 5 of 6
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CERTIFICATE OF SERVICE

I hereby certify that I have on this 23rd day of November, 2010, a copy of the foregoing pleading 

was filed electronically with the Clerk of Court using the CM/ECF system. Notice of this filing will be 

sent to all counsel of record registered to receive electronic service by operation of the court’s electronic 

filing system. I also certify that I have mailed this filing by United States Postal Service to all counsel of 

record who are not registered to receive electronic service by operation of the court’s electronic filing 

system. 

 /s/ Mark M. Barber

 Mark M. Barber 

Case 4:10-cv-00486-SPM -WCS Document 22 Filed 11/23/10 Page 6 of 6