• Dixey

BP Track Record

BP Track Record

Civil Action Suit – UNITED STATES OF AMERICA,PLAINTIFF,v. AIG TRADING

CORPORATION; BP EXPLORATION & OIL INC.; and CARGILL INTERNATIONAL, S.A.

Defendants.

Beginning at least as early as July 1992, and continuing at least until May

1993, the exact dates being unknown to the United States, the defendants and

their co-conspirators engaged in a combination and conspiracy in

unreasonable restraint of interstate trade and commerce in violation of

Section 1 of the Sherman Act, as amended (15 U.S.C. § 1). This unlawful

combination and conspiracy may be renewed unless the relief prayed for

herein is granted.

http://www.justice.gov/atr/cases/f1300/1345.htm

*

FEBRUARY 7, 1995 – BRITISH PETROLEUM AGREES TO PAY $3.9 MILLION FOR 1990

CALIFORNIA OIL SPILL (tanker accident)

http://www.justice.gov/opa/pr/Pre_96/February95/72.txt.html

*

MARCH 15, 1999 – BP OIL MUST MONITOR FLARING OF GASES AT TOLEDO REFINERY.

Company To Also Pay $1.75M To Settle Environmental Charges.

http://www.justice.gov/opa/pr/1999/March/092enr.htm

*

SEPTEMBER 23, 1999 – BP Exploration [Alaska] Pleads Guilty To Hazardous Substance Crime. Will Pay$22 Million, Establish Nationwide Environmental Management System.

http://www.justice.gov/opa/pr/1999/September/437enr.htm

*

APRIL 11, 2000 – BP AMOCO AGREES TO PAY $32 MILLION TO RESOLVE CLAIMS OF

UNDERPAYMENT OF OIL ROYALTIES. BP Amoco has agreed to pay $32 million to

resolve claims under the False Claims Act and administrative claims that the

corporation underpaid royalties due for oil produced on federal and Indian

leases since 1988, the Justice Department announced today. BP Amoco, which

is based in Chicago, was created in 1998 by the merger of Amoco Corporation

of the United States and the British Petroleum Company p.l.c. of the United

Kingdom.

http://www.justice.gov/opa/pr/2000/April/196civ.htm

*

NOVEMBER 5, 2004 – EPA TO RECEIVE $62 MILLION FOR PAST CLEANUP COSTS. Under

the consent decree, EPA will receive $50 million in payments from Atlantic

Richfield Company-a subsidiary of British Petroleum, commonly known as

ARCO-and another $12 million from the US Judgement Fund, for a total of $62

million. The consent decree was negotiated to cover EPA cleanup costs in the

Clark Fork Basin from the early 1980s until July 31, 2002.

http://www.justice.gov/opa/pr/2004/November/04_enrd_734.htm

*

AUGUST 2, 2005 – $100 MILLION SETTLEMENT REACHED FOR CLEANUP OF THE MILLTOWN

RESERVOIR. The Atlantic Richfield Company (a BP subsidiary) and the

NorthWestern Corporation have agreed to complete a $100 million-plus cleanup

of the Milltown Reservoir, removing millions of cubic yards of contaminated

sediments and decommissioning and removing the Milltown Dam, the Department

of Justice and the Environmental Protection Agency announced today. The

State of Montana and the Confederated Salish and Kootenai Tribes are also

signatories to the settlement.

http://www.justice.gov/opa/pr/2005/August/05_enrd_397.htm

*

JUNE 28, 2006 – Former BP North America Trader Pleads Guilty to Conspiracy

to Manipulate and Corner the Propane Market

http://www.justice.gov/opa/pr/2006/June/06_crm_401.html

http://www.justice.gov/criminal/pr/2006/06/2006_4649_2_CRM_06-401_fraud_bp_abbott_info.pdf

http://www.fbi.gov/stats-services/publications/fcs_report2006/financial-crimes-report-to-the-public-2006-pdf

*

OCTOBER 25, 2007 – British Petroleum and several of its subsidiaries have

agreed to pay approximately $373 million in fines and restitution for

environmental violations stemming from a fatal explosion at a Texas refinery

in March 2005, leaks of crude oil from pipelines in Alaska, and fraud for

conspiring to corner the market and manipulate the price of propane carried

through Texas pipelines.

http://www.justice.gov/opa/pr/2007/October/07_ag_850.html

http://www.justice.gov/enrd/3509.htm

*

2008 – States v. British Petroleum Exploration (Alaska), Inc. (BPXA)

In United States v. British Petroleum Exploration (Alaska), Inc. (BPXA), the

corporate defendant failed to heed the many warning signs of imminent

internal corrosion of oil transit lines that a reasonable operator should

have recognized.  This failure resulted in more than 200,000 gallons of

crude oil on the North Slope spreading over two acres of tundra.  BPXA’s

failure to allocate sufficient resources, due to cost-cutting measures, led

to the failure of a section of the oil transit line which had not been

inspected for eight years.   BPXA pled guilty to a CWA violation for the

largest-ever spill of crude oil on the north slope of Alaska.  BPXA was

sentenced to pay a $20 million fine, followed by a 3-year term of probation.

Four million dollars will be used for research in support of the arctic

environment in the State of Alaska on the North Slope, and $4 million in

restitution will be paid to the State of Alaska.   A second spill involving

approximately 1,000 gallons of oil, which led to the shutdown of Prudhoe Bay

oil production on the eastern side of the field, was also covered by the

plea agreement.

http://www.justice.gov/enrd/ENRD_Assets/ENRD_2008_Accomplishments_Report_Final.pdf

*

June 12, 2010 – Robert L. Rinke, individually, and on behalf of all others similarly situated, Plaintiffs

vs.

BP, P.L.C.,

BP Products North America, Inc.,

BP Corporation of North America, Inc.,

BP Exploration and Production, Inc.

BP America, Inc., Anthony Hayward,

and John and Jane Doe, 1-100

Defendants

Class Action Complaint

…to recover damages to Plaintiffs and others similarly situated. Plaintiffs’ damages were caused by Defendants’ scheme to secure billions of dollars in profits by committing a pattern of criminal acts including mail and wire fraud through submissions in the permitting process for offshore drilling.

…The action is brought under the federal RICO statue … and the Florida Civil remedies for Criminal Practices Act (comminly referred to as "Florida Civil RICO" or "Florida RICO").


http://cdn.levinlaw.com/pdf/06.12.10-RICO-Complaint.pdf

*

September 30, 2010 – BP Products to Pay Largest Single-facility Clean Air

Act Penalty for Releases of Hazardous Pollutants at Texas City Refinery.

$15 Million Penalty Resolves Federal Claims Stemming from Two Fires, Leak

and Reporting Violations at Refinery.

http://www.justice.gov/opa/pr/2010/September/10-enrd-1103.html

*

December 15, 2010 – UNITED STATES OF AMERICA, Plaintiff, v.BP EXPLORATION &

PRODUCTION INC., ANADARKO EXPLORATION & PRODUCTION LP, ANADARKO PETROLEUM

CORPORATION, MOEX OFFSHORE 2007 LLC, TRITON ASSET LEASING GMBH, TRANSOCEAN

HOLDINGS LLC, TRANSOCEAN OFFSHORE DEEPWATER DRILLING INC., TRANSOCEAN

DEEPWATER INC., AND QBE UNDERWRITING LTD., LLOYD’S SYNDICATE 1036,

Defendants.

UNITED STATES DISTRICT COURT, EASTERN DISTRICT OF LOUISIANA. Case

2:10-cv-04536, Document 1, Filed 12/15/10.

http://www.justice.gov/usao/lae/news/2010/downloads/complaint_12152010.pdf

*

Jan. 24, 2011 – Case 2:10-md-02179-CJB-SS (PLAINTIFFS’ RICO CASE STATEMENT)

Document 1059-1 Filed 01/24/11 Page 1 of 18

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

In Re: Oil Spill by the Oil Rig )

“Deepwater Horizon” in the Gulf ) MDL No. 2179

of Mexico, on April 20, 2010 )

) SECTION: J

Pleading Applies To: )

All Cases in Pleading Bundle B2 ) JUDGE BARBIER

)

) MAGISTRATE SUSHAN

PLAINTIFFS’ RICO CASE STATEMENT

Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 2 of 18

Pursuant to this Court’s Order of January 18, 2011 and the standing order of the Eastern District of Louisiana, Plaintiffs file the following RICO Case Statement:

1.  State whether the alleged unlawful conduct is in violation of 18 U.S.C.

Sections 1962(a), (b), (c), and/or (d). If you allege violations of more than one

Section 1962 subsection, treat each as separate RICO claim.

The alleged unlawful conduct is in violation of 18 U.S.C. Sections 1962(c).

The alleged unlawful conduct is in violation of 18 U.S.C. § 1962(d) for conspiring to

violate § 1962(c).

The alleged unlawful conduct is in violation of 18 U.S.C. 1962 (d) for conspiring to

violate 18 U.S.C. § 1962(a).

2.  List each defendant and state the alleged misconduct and basis of liability of

each defendant.

BP Exploration & Production, Inc. (“BP Exploration”) is a Delaware corporation with its

principal place of business in Warrensville, Illinois. BP Exploration was a lease holder

and the designated operator in the lease granted that allowed the oil exploration, drilling

and production-related operations in the location where the spill emanating from the

Deepwater Horizon originated. BP Exploration participated and conspired to participate

in the predicate acts that form the pattern of racketeering alleged below.

BP America Production Company (“BP America”) is a Delaware corporation with its

principal place of business in Houston, Texas. BP America was the party to the Drilling

Contract with Transocean Ltd. for the drilling of the Macondo well by the Deepwater

Horizon vessel. BP America participated and conspired to participate in the predicate

acts that form the pattern of racketeering alleged below.

BP p.l.c. is a British public limited company with its corporate headquarters in London,

England. BP p.l.c. is the global parent company of the worldwide business operating

under the “BP” logo. BP p.l.c. participated and conspired to participate in the predicate

acts that form the pattern of racketeering alleged below.

BP Exploration, BP America, and BP p.l.c. are generally referred to herein collectively as

“BP.”

3.  List the alleged wrongdoers, other than the defendants listed above, and state

the alleged misconduct of each wrongdoer.

Other possible wrongdoers involved in the pattern of racketeering include the following,

although at this point the full extent of their involvement is unknown:

2 Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 3 of 18

Transocean Ltd. (“Transocean Ltd.”) is a Swiss corporation that maintains substantial

U.S. offices in Houston, Texas, and that at all pertinent times was doing business in the

State of Louisiana and within this district. Transocean Ltd. was an owner, managing

owner, owner pro hac vice, and/or operator of the Deepwater Horizon. Transocean

Ltd. participated and conspired to participate in overt acts in furtherance of the pattern of

racketeering alleged below.

Transocean Offshore Deepwater Drilling, Inc. (“Transocean Offshore”) is a Delaware

corporation with its principal place of business in Houston, Texas. Transocean Offshore

is affiliated with Transocean Ltd. and was an owner, managing owner, owner pro hac

vice, and/or operator of the Deepwater Horizon. Transocean Offshore participated and

conspired to participate in overt acts in furtherance of the pattern of racketeering alleged

below.

Transocean Deepwater, Inc. (“Transocean Deepwater”), is a Delaware corporation with

its principal place of business in Houston, Texas. Transocean Deepwater is affiliated with

Transocean Ltd. and was an owner, managing owner, owner pro hac vice, and/or

operator of the Deepwater Horizon. Transocean Deepwater participated and conspired to

participate in overt acts in furtherance of the pattern of racketeering alleged below.

Transocean Holdings, LLC (“Transocean Holdings”) is a Delaware corporation with its

principal place of business in Houston, Texas. Transocean Holdings is affiliated with

Transocean Ltd. and is a wholly-owned subsidiary of Transocean Offshore. Transocean

Holdings is an owner, managing owner, owner pro hac vice, and/or operator of the

Deepwater Horizon. Transocean Holdings participated and conspired to participate in

overt acts in furtherance of the pattern of racketeering alleged below.

Triton Asset Leasing GmbH (“Triton”) is a Swiss limited liability company with its

principal place of business in Zug, Switzerland. Triton is affiliated with Transocean Ltd.

and is an owner, managing owner, owner pro hac vice, and/or operator of the

Deepwater Horizon. Triton participated and conspired to participate in overt acts in

furtherance of the pattern of racketeering alleged below.

Transocean Ltd., Transocean Deepwater, Transocean Offshore, Transocean Holdings,

and Triton are hereinafter referred to collectively as “Transocean.”

Halliburton Energy Services, Inc. (“Halliburton”) is a Delaware corporation with its

principal place of business in Houston, Texas. Halliburton provided engineering

services, materials, testing, mixing, and pumping for cementing operations on board the

Deepwater Horizon, as well as onshore engineering support for those operations.

Subject to discovery of information in the hands of the Defendant, Plaintiffs may

determine that Halliburton participated and conspired to participate in overt acts in

furtherance of the pattern of racketeering activity alleged below.

Halliburton division Sperry Drilling Services (“Sperry”) (formerly Sperry Sun Drilling

Services) was responsible for mudlogging personnel and equipment on the Deepwater

3 Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 4 of 18

Horizon, including downhole drilling tools. Subject to discovery of information in the

hands of the Defendant, Plaintiffs may determine that Sperry participated and conspired

to participate in overt acts in furtherance of the pattern of racketeering activity alleged

below.

“Halliburton” shall refer to both Halliburton Energy Services, Inc. and its Sperry

division.

Cameron International Corporation f/k/a Cooper-Cameron Corporation (“Cameron”) is a

Delaware corporation with its principal place of business in Houston, Texas. Cameron

is registered to do and does business in the State of Louisiana. Cameron manufactured,

designed, supplied, and/or installed the Deepwater Horizon’s sub-sea emergency well-

closure device known as a blowout-preventer (“BOP”), which is, and was at all material

times, an appurtenance of the vessel and a part of the vessel’s equipment. Subject to

discovery of information in the hands of the Defendant, Plaintiffs may determine that

Cameron participated and conspired to participate in overt acts in furtherance of the

pattern of racketeering activity alleged below.

M-I, LLC (“M-I”) is a Delaware limited liability company with its principal place of

business in Wilmington, Delaware. M-I, also known as M-I SWACO, supplies drilling

and completion fluids and additives to oil and gas companies in Louisiana and

elsewhere, providing pressure control, vessel instrumentation, and drilling waste

management products and services. On the Deepwater Horizon, M-I provided mud

products, including drilling fluids and spacers, engineering services, and mud

supervisory personnel, such as mud engineers and drilling fluid specialists, to manage

the properties of those fluids in the well. M-I employees planned and/or supervised key

fluid-related activities at Macondo, such as the mud displacement that was occurring at

the time of the April 20, 2010, blowout. Subject to discovery of information in the

hands of the Defendant, Plaintiffs may determine that M-I participated and conspired to

participate in overt acts in furtherance of the pattern of racketeering activity alleged

below.

Weatherford U.S. L.P. (“Weatherford”) is a Louisiana limited partnership that maintains

its principal place of business in Houston, Texas. Weatherford designed and

manufactured, marketed, sold, and/or distributed the casing components such as the float

collar, shoe, and centralizers appurtenant to the vessel, and provided the personnel and

equipment for running the casing and casing components into the wellbore. Subject to

discovery of information in the hands of the Defendant, Plaintiffs may determine that

Weatherford participated and conspired to participate in overt acts in furtherance of the

pattern of racketeering activity alleged below.

Anadarko Petroleum Corporation Co. (“Anadarko”) is a Delaware corporation with its

principal place of business in The Woodlands, Texas. Anadarko is an oil and gas

exploration and production company. Anadarko E&P Company LP (“Anadarko E&P”)

is a Delaware limited partnership with its principal place of business in The Woodlands,

Texas. Anadarko E&P is an oil and gas exploration and production company. MOEX

4  Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 5 of 18

Offshore 2007 LLC (“MOEX Offshore”) is a Delaware corporation with its principal

place of business in Houston, Texas. MOEX Offshore is a wholly-owned subsidiary of

MOEX USA Corporation. MOEX USA Corporation (“MOEX USA”) is incorporated in

Delaware and has its principal place of business in Houston, Texas. MOEX USA is the

parent company of MOEX Offshore. Mitsui Oil Exploration Co., Ltd. (“MOECO”) is

incorporated in Japan and has its principal place of business in Tokyo, Japan. As of

June 30, 2010, MOECO identified itself as having the following U.S. subsidiaries or

affiliates: MitEnergy Upstream LLC, MOEX USA Corporation, MOEX Offshore 2007

LLC, MOEX Gulf of Mexico Corporation, MOEX Oil & Gas Texas LLC, and Mitsui

E&P USA LLC. Each of these subsidiaries of MOECO share the same Houston, Texas,

address. Defendants MOEX Offshore, MOEX USA, and MOECO are referred to

collectively herein as “MOEX.” While BP was the sole lease operator of the

Deepwater Horizon, Anadarko, Anadarko E&P, and MOEX were considered non-

operational leaseholders. On October 1, 2009, BP Exploration, as operator, and MOEX

Offshore, as non-operator, entered into the Macondo Prospect Offshore Deepwater

Operating Agreement. On December 17, 2009, BP Exploration, MOEX Offshore,

Andarko E&P, and Andarko executed a "Joinder" of the Operating Agreement.

Subsequently, the parties to the Operating Agreement held the following ownership

percentages in the Macondo Prospect: BP Exploration, 65%; MOEX Offshore, 10%;

Anadarko E&P, 22.5%; and, Anadarko, 2.5%. According to the MMS’s website,

effective April 1, 2010, record title interest in the Macondo prospect was held as

follows: BP Exploration, 65%; MOEX Offshore, 10%; and, Anadarko, 25%. Subject to

discovery of information in the hands of the Defendant, Plaintiffs may determine that

Anadarko and MOEX participated and conspired to participate in overt acts in

furtherance of the pattern of racketeering activity alleged below.

The former Minerals Management Service (“MMS”) was a federal entity created in 1982,

intended to serve as the designated agency responsible for the mineral leasing of

submerged lands of the Outer Continental Shelf, including the supervision of the

Deepwater Horizon drilling operations. The MMS was reorganized as the Bureau of

Ocean Energy Management, Regulation, and Enforcement (BOEMRE) on June 18, 2010;

however, it shall be referred to as the MMS throughout this document. Subject to

discovery of information in the hands of the Defendant, Plaintiffs may determine that

certain dishonest MMS employees participated and conspired to participate in overt acts

in furtherance of the pattern of racketeering activity alleged below.

The Marine Preservation Association (“MPA”) is a consortium of major oil industry

companies, including BP, Chevron, Exxon-Mobil, Shell and Conoco Phillips, created in

response to the 1990 Oil Pollution Act, which required that anyone involved in the

transportation, distribution or receipt of petroleum products on water must establish an

approved plan that—should they cause a significant oil spill, responds to the “maximum

extent practicable.” The MPA funds the Marine Spill Response Corporation (“MSRC”),

which has been held out by Defendants as the “largest, most dedicated standby oil spill

response program in the United States.” The above oil companies all utilized the

Response Group to prepare the plans submitted to the MMS that contain

misrepresentations and omissions regarding their ability to respond to and contain

5  Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 6 of 18

deepwater oil spills. Subject to discovery of information in the hands of the Defendant,

Plaintiffs may determine that the above oil companies colluded through the above

entities to misrepresent their ability to contain a deepwater oil spill and thereby

participated and conspired to participate in overt acts in furtherance of the pattern of

racketeering activity alleged below.

4.  List the alleged victims and state how each victim allegedly was injured.

The named plaintiffs and their injuries are as follows:

Plaintiff, Robert L. Rinke owns and resides at 18 Via De Luna Drive, Beach Club

Penthouse #6, Pensacola Beach, Florida 32561. The Beach Club Resort and Spa is a 130

unit condominium complex located on the Gulf of Mexico, Pensacola Beach, Escambia

County, Florida. Due to the Spill, Plaintiff Rinke has suffered the loss, damage and

diminution in value of his condominium property abutting the Gulf of Mexico.

Plaintiff, Armand’s Bistro LLC, is a domestic limited liability company domiciled and

doing business in Louisiana. Armand’s Bistro was a seafood restaurant located inside the

Holiday Inn on Highway 51 in LaPlace, Louisiana. Due to the Spill, it could not obtain

the seafood it needed to operate, and had to close.

Plaintiffs Roland and Barbara Hingle reside at 151 Bouson Lane, Buras, Louisiana. The

Hingles are commercial shrimpers in the Gulf of Mexico who have lost earnings and

property from the Spill.

Plaintiff Alan Sheen, M.D. is a resident of Louisiana who resides in this district and owns

property in Florida—a condominium with the address of Sundunes 112, 7979 Gulf Blvd.,

Navarre Beach, Florida. Dr. Sheen has owned the condominium for more than five years.

In 2010, his rental income was less than half the average of the prior two years, due to the

Spill.

Plaintiff Mid South Seafood, Inc. is a Mississippi corporation doing business throughout

the state of Mississippi. Plaintiff is a seafood business that buys seafood from the Gulf of

Mexico on the Gulf Coast and sells the seafood throughout Mississippi. Due to the Spill,

Plaintiff Mid South Seafood has lost business and earnings.

The alleged class members—all victims—fall into nine basic categories, all of whom

were injured in their business or property as a result of the Deepwater Horizon oil spill.

In presenting these categories of victims in the following order, Plaintiffs do not suggest

or imply any hierarchy of merit, preference, or importance:

(a)

Commercial fishermen, shrimpers, crabbers, oystermen, the

owners and operators of businesses involving commercial fishing,

shrimping, crabbing and oystering (the “Commercial Fishermen

Plaintiffs”).

6   Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 7 of 18

(b) Seafood processors, distributors, retail and seafood markets, and

restaurant owners and operators, and all those employed by

seafood processors, distributors, retail and seafood markets, and

restaurants (the “Processing and Distributing Plaintiffs”).

(c) Recreational business owners, operators, and/or workers, including

recreational fishing businesses, commercial guides, and charter

fishing businesses who earn their living through the use of the Gulf

of Mexico for businesses (the “Recreational Business Plaintiffs”).

(d)  Commercial businesses, business owners, operators, and/or

workers, including commercial divers, offshore oilfield service,

repair, and supply, real estate agents, and supply companies and

their employees (the “Commercial Business Plaintiffs”).

(e)  Recreational sport fishermen, recreational divers, beachgoers, and

recreational boaters (the “Recreation Plaintiffs”).

(f)  Plant and dockworkers, including commercial seafood plant

workers, longshoremen, and ferry operators (the “Plant and Dock

Worker Plaintiffs”). Owners, lessors, and lessees of real property,

alleged to be damaged, harmed, or impacted, physically or

economically, including but not limited to condominium owners

along the Gulf Coast that suffered economic loss through

diminution in their property value and lessees of oyster beds (the

“Real Property Plaintiffs”).

(g)  Hotel owners and operators, vacation rental owners and agents,

and all those who earn their living from the tourism industry (the

“Real Property/Tourism Plaintiffs”).

(h)  Banks, financial institutions, and retail businesses that suffered

losses as a result of the Spill (the “Banking/Retail Business

Plaintiffs”).

(i)  Persons who utilize natural resources for subsistence (the

“Subsistence Plaintiffs”).

5.

Describe in detail the pattern of racketeering activity or collection of an

unlawful debt alleged for each RICO claim. A description of the pattern of

racketeering activity shall include the following information:

(a)

List the alleged predicate acts and the specific statutes allegedly

violated;

The predicate acts constitute violations of mail fraud under 18 U.S.C. § 1341 and wire

7

Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 8 of 18

fraud under 18 U.S.C. § 1343. These predicate acts form the pattern of racketeering and

are the basis of BP’s violation of 18 U.S.C. § 1962(c). These predicate acts also

constitute the primary overt acts taken in furtherance of the conspiracies under 18 U.S.C.

§ 1962(d) to violate 18 U.S.C. §§ 1962(c) and (a).

(b)

Provide the dates of the predicate acts, the participants in the

predicate acts and a description of the facts surrounding each

predicate act;

See response to 5(c), below.

(c)

If the RICO claim is based upon the predicate offenses of wire fraud,

mail fraud, fraud in the sale of securities, or fraud in connection with

a case under U.S.C. Title 11, the “circumstances constituting fraud or

mistake shall be stated with particularity,” Fed. R. Civ. P. 9(b).

Identify the time, place, and contents of the alleged misrepresentation

or omissions, and the identity of persons to whom and by whom the

alleged misrepresentations or omissions were made;

The facts and details such as time, place, content of misrepresentations and omissions,

and identity of persons or the government entity to whom and by whom the alleged

misrepresentations and omissions were made that are known to date constituting the

predicate acts are:

i.

Upon information and belief, on December 1, 2000, BP submitted

by mail and/or interstate wire or interstate carrier to MMS a

Regional Oil Response Plan addressing the entire Gulf of Mexico

area, including the area later drilled by the Deepwater Horizon.

This plan falsely stated that BP could contain an oil spill of up to

250,000 barrels per day. This plan included other blatant

misrepresentations, such as: an ability to haul out sea lions, seals

and walruses; links to a Japanese home shopping website as being

one of the “primary equipment providers for BP in the Gulf of

Mexico region [for] rapid deployment of spill response resources.”

BP Regional Oil Response Plan – Gulf of Mexico.

ii.

Upon information and belief, on June 30, 2009, BP submitted by

mail and/or interstate wire or interstate carrier to MMS a revised

Regional Oil Response Plan addressing the Gulf of Mexico, that

included the same misrepresentations as the prior plan. It also

added new misrepresentations, such as references to a professor

8

Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 9 of 18

listed as a consultant for responding to the spill who had died in

2005.

iii.

Upon information and belief, on February 23, 2009, BP submitted

by mail and/or interstate wire or interstate carrier to MMS an

Initial Exploration Plan for Mississippi Canyon Block 252 – the

document covering the Macondo project. In this document, BP

falsely minimized the prospect of any serious damage associated

with a spill, saying there would be only “sub-lethal” effects on

fish and marine mammals, and “birds could become oiled.” BP

further misrepresented that “[i]n the event of an unanticipated

blowout resulting in an oil spill, it is unlikely to have an impact

based on the industry wide standards for using proven equipment

and technology for such responses, implementation of BP’s

Regional Oil Spill Response Plan which address available

equipment and personnel, techniques for containment and

recovery and removal of the oil spill.” [emphasis added]. BP also

falsely stated that it was prepare to handle a worst-case discharge

of 162,000 barrels of oil per day.

iv.

Interstate wires were used on March 25, 2010 and March 30, 2010

to further BP’s scheme to defraud the MMS. Emails on those dates

were sent among BP personnel, and concluded that the long string

casing design would “save a lot of time…at least 3 days,” “saves a

good deal of time/money,” and is the “[b]est economic case.”

Email from Brian Morel, BP Drilling Engineer, to Allison Crane,

Materials Management Coordinator, March 25, 2010; Email from

Brian Morel, BP Drilling Engineer, to Sarah Dobbs, Completion

Engineer, March 30, 2010. Despite the fact the BP itself had

concluded that it would not use the long string casing design

because of the high risk of a failed cement job and the inability to

comply with MMS regulations, BP then on April 15, 2010 sent by

mail and/or interstate wire or interstate carrier a request to MMS

asking for a permit to use long string casing, apologizing for not

having mentioned its use earlier and falsely stating that they had

“inadvertently” failed to include its use in earlier submitted plans.

v.

Similarly, interstate wires were used on March 25, 2010 to further

BP’s scheme to defraud the MMS when Brian Morel of BP sent an

email to Heather Powell, copied to Scherie Douglas, Senior

Regulatory Compliance Team Lead at BP, stating in part with

respect to obtaining a bypass permit: “I have attached what I feel

is pertinent data, only thing missing from the documents we

submitted for the bypass permit is the engineering calculations, as

they don’t completely pertain to this liner, hopefully they will not

ask for them. However if they do want them I can provide.” This

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Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 10 of 18

email reflects an intent to knowingly provide insufficient

documentation to MMS and then, if caught with respect to the

insufficient documentation, provide incorrect documentation.

vi.

BP used the interstate wires in furtherance of its scheme, in

particular as the scheme was implemented to place profit above

safety with respect to the use of pipe centralizers. BP knowingly

chose an insufficient number of “centralizers” to prevent

channeling of gas during the cementing process. Halliburton, the

contractor hired by BP to cement the well, warned BP that the well

could have a “SEVERE gas flow problem” if BP lowered the final

string of casing with only six centralizers instead of 21

recommended by Halliburton. BP rejected Halliburton’s advice to

use additional centralizers, solely because the delay it would entail.

In an April 16, 2010 email, a BP executive involved in the

decision-making explained: “it will take 10 hours to install

them…I do not like this.” Later that day, another BP official

knowingly acknowledged the increased risk of proceeding without

a sufficient number of centralizers, but carelessly commented with

lethal disregard for the people and the environment that could be

seriously injured, causing further injury to business or property:

“who cares, it’s done, end of story, will probably be fine. . . .”

(Email from Brett W. Cocales to Brian P. Morel, April 16, 2010).

vii.

According to the National Commission report, on April 16, 2010

BP sent, upon information or belief by mail or interstate wire, an

Application for Permit to Modify to MMS describing a temporary

abandonment procedure that was different from the procedure in

either the April 12 drilling plan, an April 14 email, or an April 20

“Ops Note.” There is no evidence that these changes went through

any sort of formal risk assessment or management of change

process as required.

Upon information and belief, numerous other acts of mail and wire fraud will be

uncovered in discovery, because the bulk of relevant mails and wires currently are in the

hands of BP and its co-conspirator Transocean.

(d)

Describe whether the alleged predicate acts relate to the enterprise as

part of a common plan. If so, describe in detail.

The alleged predicate acts relate to the association-in-fact enterprise of BP and

Transocean as part of a common plan to place profits over safety by: (1) fraudulently

deceiving federal and state regulators that they would safely conduct their offshore oil

drilling operations to prevent oil spills, (2) fraudulently deceiving federal and state

regulators that they could effectively respond to and contain any oil spill, including worse

case scenario oil spills like the Deepwater Horizon disaster, (3) hampering containment

10

Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 11 of 18

and cleanup responses by fraudulently deceiving federal and state regulators regarding

the oil spill flow rate; and (4) fraudulently deceiving federal and state regulators

regarding the quickest and safest method to kill the Macondo well and stop the Spill.

Defendant BP participated in and conspired with Transocean to engage in one or more of

these schemes. BP individually, and BP in conjunction with its co-conspirator

Transocean, used the association-in-fact enterprise of BP and Transocean to carry out this

common plan.

6.

Describe in detail the alleged enterprise for each RICO claim. A description

of the enterprise shall include the following information;

(a)

State the names of the individuals, partnerships, corporations,

associations or other entities allegedly constituting the enterprise;

BP and Transocean constitute the association-in-fact enterprise, within the meaning of 18

U.S.C. § 1961(4), for Plaintiffs’ 18 U.S.C. § 1962(c) claim, for Plaintiffs’ 18 U.S.C. §

1962(d) RICO claim for conspiracy to violate 18 U.S.C. § 1962(c), and for Plaintiffs’ 18

U.S.C. § 1962(d) claim for conspiracy to violate 18 U.S.C. § 1962(a).

(b)

Describe the structure, purpose, roles, function and course of conduct

of the enterprise;

The structure of the enterprise is an association-in-fact between BP and Transocean. The

purpose, role, function and course of conduct of the enterprise is in part to carry out the

lawful business of exploring and developing oil reserves, and in part to carry out the

pattern of racketeering described in answer to question No. 5, above. The enterprise

possessed and continues to possess an ongoing organizational structure.

(c)

State whether any defendants are employees, officers or directors of

the alleged enterprise;

Defendant BP is not an employee, officer or director of the alleged enterprise.

(d)

State whether any defendants are associated with the alleged

enterprise, and if so, how;

Defendant BP is associated with alleged enterprise both as a member of the association

in-fact enterprise, and an entity engaged in the management, operation and control of the

enterprise.

(e)

State whether you allege that the defendants are individuals or entities

separate from the alleged enterprise, or that the defendants are the

enterprise itself, or members of the enterprise;

Defendant BP is a member of the association-in-fact enterprise.

11

Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 12 of 18

(f)

If you alleged any defendants to be the enterprise itself, or members

of the enterprise, explain whether such defendants are perpetrators,

passive instruments, or victims of the alleged racketeering activity.

Defendant BP is a perpetrator of the alleged racketeering activity.

7.

State whether you allege and describe in detail how the pattern of

racketeering activities and the enterprise are separate or have merged into

one entity.

The Enterprise exists separate and apart from its pattern of racketeering activity,

inasmuch as BP and association-in-fact member Transocean have multiple goals, not all

of which are fraudulent.

8.

Describe the alleged relationship between the activities of the enterprise and

the pattern of racketeering activity. Discuss how the racketeering activity

differs from the usual and daily activities of the enterprise, if at all.

The lawful activity engaged in by the Enterprise includes ongoing partnerships between

BP and Transocean to explore and develop oil reserves. But Defendant BP has, at a

minimum since 2001, also used this enterprise to conduct the related acts of mail and

wire fraud comprising the pattern of racketeering.

9.

Describe what benefits, if any, the alleged enterprise receives from the

alleged pattern of racketeering activities.

The Enterprise benefits from the alleged pattern of racketeering activity by obtaining

billions of dollars in oil and profits through the pattern of racketeering activity that misled

the government regulators into believing the Enterprise was using the best available and

safest technology to conduct its offshore drilling operations and contain any spills. The

mail and wire fraud constituting the pattern of racketeering activities was necessary for

the Enterprise to receive this benefit, because absent the pattern of racketeering the

regulators would have required BP and co-conspirator Transocean to expend the funds

necessary to comply with regulatory requirements, or forego the profitable activities.

Government regulators would not have allowed the Enterprise to conduct its offshore

exploration, development and containment activities in a knowingly unsafe manner.

10.

Describe the effect of the activities of the enterprise on interstate or foreign

commerce.

At all relevant times, the activities of the Enterprise substantially affected interstate and

foreign commerce, through and including but not limited to, its large investments,

expenditures and offshore drilling activities with numerous entities involved in its

ongoing offshore drilling in the Gulf of Mexico and around the world.

12

Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 13 of 18

11.

If the complaint alleges a violation of 18 U.S.C. Section 1962 (a), provide the

following information:

(a)

State who received the income derived from the pattern of

racketeering activity or through the collection of an unlawful debt;

and,

(b)

Describe the use or investment of such income.

Not applicable.

12.

If the complaint alleges a violation of 18 U.S.C. Section 1962 (b), provide the

following information:

(a)

Describe in detail the acquisition or maintenance of any interest in or

control of the alleged enterprise; and,

(b)

State whether the same entity is both the liable “person” and the

“enterprise” under Section 1962 (b).

Not applicable.

13.

If the complaint alleges a violation of 18 U.S.C. Section 1962 (c), provide the

following information:

(a)

State who is employed by or associated with the enterprise;

Defendant BP is associated with the Enterprise.

(b)

State whether the same entity is both the liable “person” and the

“enterprise” under Section 1962 (c).

Defendant BP is not both the liable “person” and the “enterprise” under Section 1962(c).

14.

If the complaint alleges a violation of 18 U.S.C. Section 1962 (d), describe in

detail the alleged conspiracy.

As described in more detail in response to 5(c) and in the Complaint, Defendant BP

conspired with Transocean to mislead government regulators into believing they were

safely conducting offshore drilling operations and that they could safely contain

deepwater oil spills. Defendant BP and Transocean conspired under Section 1962(d) to

violate Section 1962(c) and undertook overt acts of mail and wire fraud in furtherance of

that conspiracy. Similarly, Defendant BP and Transocean conspired under Section

1962(d) to violate Section 1962(a) by undertaking overt acts of mail and wire fraud in an

effort to use or invest income unlawfully derived from such conduct, directly or

indirectly, in the establishment or operation of the association-in-fact Enterprise. BP and

13

Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 14 of 18

Transocean both agreed to the objective of the conspiracy. The specifics of some of the

knowing interactions evidencing this conspiracy are set forth in more detail in response to

5(c), above, and some of the specifics will be secured in discovery since such additional

evidence supporting these conspiracy claims is in the hands of Defendant BP and coconspirator

Transocean.

15.

Describe the alleged injury to business or property.

The RICO violations caused the spill and the failure to effectively contain the spill, which

was the direct and proximate cause of injury to business or property of Plaintiffs. The

injury to business or property of the named Plaintiffs and class members is more fully

described in response to question No. 4, above.

16.

Describe the relationship between the alleged injury and violation of the

RICO statute.

The violation of the RICO statute is the direct and proximate cause of the injuries

suffered by the victim/plaintiffs in this case. The scheme to defraud regulators regarding

the safety of Defendants’ deep sea oil drilling allowed Defendants to proceed with the

Deepwater Horizon drilling without prescribed and claimed safeguards that would have

prevented the spill, causing the spill and the consequent damage to Plaintiffs’ business

and property. The scheme to defraud regulators regarding Defendants’ ability to contain

a spill allowed Defendants to proceed with the Deepwater Horizon drilling without a

prescribed and claimed containment plan in place, exacerbating the spill and the

consequent injury and damage to Plaintiffs’ business and property.

17.

List the damages sustained by reason of the violation of Section 1962,

indicating the amount for which each defendant allegedly is liable.

The damages sustained by reason of the violation of Section 1962 are ongoing, but to

date clearly number in the billions of dollars. Defendant BP is liable for the injury to

Plaintiffs and class members and all damages. Plaintiffs reserve the right to amend the

Complaint to add additional Defendants that are liable for the injury and damages to

Plaintiffs and class members.

18.

List all other federal causes of action, if any, and provide the relevant statute

numbers.

No other federal cause of action is set forth in the B2 Master Complaint. Plaintiffs reserve

the right to add additional federal causes of action against BP and/or additional

Defendants.

19.

List all pendent states claim, if any.

Plaintiffs also seek equity relief under FLA. STAT. ANN. §§ 895.05 (1), (6).

14  Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 15 of 18

20. Provide any additional information you feel would be helpful to the Court in

processing your RICO claim.

Plaintiffs believe their RICO claim is a straightforward application of civil RICO, and

would be pleased to answer any questions the Court may have in processing this claim.

Dated: January 24, 2011.

Respectfully submitted,

/s/ Stephen J. Herman

Stephen J. Herman, La. Bar No. 23129

HERMAN HERMAN KATZ & COTLAR LLP

820 O’Keefe Avenue

New Orleans, Louisiana 70113

Telephone: (504) 581-4892

Fax No. (504) 569-6024

E-Mail: sherman@hhkc.com

/s/ James Parkerson Roy______

James Parkerson Roy, La. Bar No. 11511

DOMENGEAUX WRIGHT ROY & EDWARDS LLC

556 Jefferson Street, Suite 500

Lafayette, Louisiana 70501

Telephone: (337) 233-3033

Fax No. (337) 233-2796

E-Mail: jimr@wrightroy.com

Plaintiffs Liaison Counsel Plaintiffs Liaison Counsel

PLAINTIFFS’ STEERING COMMITTEE

Brian H. Barr

LEVIN, PAPANTONIO, THOMAS,

MITCHELL, ECHSNER & PROCTOR, PA

316 South Baylen St., Suite 600

Pensacola, FL 32502-5996

Office: (850) 435-7045

Telefax: (850) 436-6187

E-Mail: bbarr@levinlaw.com

Jeffrey A. Breit

BREIT DRESCHER & IMPREVENTO

999 Waterside Drive, Suite 1000

Norfolk, VA 23510

Office: (757) 670-3888

Telefax: (757) 670-3895

E-Mail: jbreit@bdbmail.com

Elizabeth J. Cabraser

LIEFF, CABRASER, HEIMANN &

BERNSTEIN, LLP

275 Battery Street, 29th Floor

Robin L. Greenwald

WEITZ & LUXENBERG, PC

700 Broadway

New York, NY 10003

Office: (212) 558-5802

Telefax: (212) 344-5461

E-Mail: rgreenwald@weitzlux.com

Rhon E. Jones

BEASLEY, ALLEN, CROW, METHVIN,

PORTIS & MILES, P. C.

218 Commerce St., P.O. Box 4160

Montgomery, AL 36104

Office: (334) 269-2343

Telefax: (334) 954-7555

E-Mail: rhon.jones@beasleyallen.com

Matthew E. Lundy

LUNDY, LUNDY, SOILEAU & SOUTH, LLP

501 Broad Street

Lake Charles, LA 70601

15

Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 16 of 18

San Francisco, CA 94111-3339

Office: (337) 439-0707

Office: (415) 956-1000

Telefax: (337) 439-1029

Telefax: (415) 956-1008

E-Mail: mlundy@lundylawllp.com

E-Mail: ecabraser@lchb.com

Michael C. Palmintier

Philip F. Cossich, Jr.

deGRAVELLES, PALMINTIER,

COSSICH, SUMICH, PARSIOLA & TAYLOR

HOLTHAUS & FRUGE’

8397 Highway 23, Suite 100

618 Main Street

Belle Chasse, LA 70037

Baton Rouge, LA 70801-1910

Office: (504) 394-9000

Office: (225) 344-3735

Telefax: (504) 394-9110

Telefax: (225) 344-0522

E-Mail: pcossich@cossichlaw.com

E-Mail: mpalmintier@dphf-law.com

Robert T. Cunningham

Paul M. Sterbcow

CUNNINGHAM BOUNDS, LLC

LEWIS, KULLMAN, STERBCOW &

1601 Dauphin Street, P. O. Box 66705

ABRAMSON

Mobile, AL 36660

601 Poydras Street, Suite 2615

Office: (251) 471-6191

New Orleans, LA 70130

Telefax: (251) 479-1031

Office: (504) 588-1500

E-Mail: rtc@cunninghambounds.com

Telefax: (504) 588-1514

E-Mail: sterbcow@lksalaw.com

Alphonso Michael “Mike” Espy

MORGAN & MORGAN, P.A.

Scott Summy

188 East Capitol Street, Suite 777

BARON & BUDD, P.C.

Jackson, MS 39201

3102 Oak Lawn Avenue, Suite 1100

Office: (601) 949-3388

Dallas, TX 75219

Telefax: (601) 949-3399

Office: (214) 521-3605

E-Mail: mike@mikespy.com

Telefax: (214) 599-1172

E-Mail: ssummy@baronbudd.com

Calvin C. Fayard, Jr.

FAYARD & HONEYCUTT

Mikal C. Watts (PSC)

519 Florida Avenue, SW

WATTS GUERRA CRAFT, LLP

Denham Springs, LA 70726

Four Dominion Drive, Building 3, Suite 100

Office: (225) 664-4193

San Antonio, TX 78257

Telefax: (225) 664-6925

Office: (210) 447-0500

E-Mail: calvinfayard@fayardlaw.com

Telefax: (210) 447-0501

E-Mail: mcwatts@wgclawfirm.com

Ervin A. Gonzalez

COLSON HICKS EIDSON

255 Alhambra Circle, Penthouse

Coral Gables, FL 33134

Office: (305) 476-7400

Telefax: (305) 476-7444

E-Mail: ervin@colson.com

16  Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 17 of 18

RICO MASTER COMPLAINT

WORKING GROUP

Hiram Eastland

EASTLAND LAW OFFICES, PLLC

307 Cotton Street

Greenwood, MS 38930

Telephone: (662) 453-1227

Facsimile: (662) 453-2808

Email: eastlandlaw@bellsouth.net

Wanda J. Edwards

FAYARD & HONEYCUTT, APC

519 Florida Avenue SW

Denham Springs, LA 70726

Telephone: (225) 664-4193

Facsimile: (225) 664-6925

Email: wandaedwards@fayardlaw.com

Keith D. Jones

8480 Bluebonnet Blvd., Suite F

Baton Rouge, LA 70810

Telephone: (225) 763-6900

Facsimile: (225)

Email: keith@kjones-law.com

W. B. Markovits

WAITE, SCHNEIDER, BAYLESS &

CHESLEY CO., L.P.A.

1513 Fourth & Vine Tower

1 West Fourth Street

Cincinnati, OH 45202

Telephone: (513) 621-0267

Facsimile: (513) 621-0262

Email: billmarkovits@wsbclaw.com

Peter Prieto

PODHURST ORSECK P.A.

25 West Flagler Street, Suite 800

Miami, FL 33130

Telephone: (305) 358-2800

Facsimile: (305) 358-2382

Email: PPrieto@podhurst.com

17

Case 2:10-md-02179-CJB-SS Document 1059-1 Filed 01/24/11 Page 18 of 18

Of Counsel:

G. Robert Blakey

Notre Dame Law School *

Notre Dame, IN 36556

Telephone: (574) 631-5717

Facsimile: (574) 631-4197

Email: G.R. Blakey.1@nd.edu

* Notre Dame Law School is used solely for purposes of address.

CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that the above and foregoing RICO Case Statement has

been served on All Counsel by electronically uploading the same to Lexis Nexis File &

Serve in accordance with Pretrial Order No. 12, and that the foregoing was electronically

filed with the Clerk of Court of the United States District Court for the Eastern District of

Louisiana by using the CM/ ECF System, which will send a notice of electronic filing in

accordance with the procedures established in MDL 2179, on this 24th day of January,

2011.

/s/ James Parkerson Roy and Stephen J. Herman

*

BP cut corners

BP cut corners in days before Deepwater Horizon blowout, resulting oil spill, documents show. BP made a series of money-saving shortcuts and blunders that dramatically increased the danger of a destructive oil spill in a well that an engineer ominously described as a "nightmare" just six days before the blowout. Time after time, it appears that BP made decisions that increased the risk of a blowout to save the company time or expense. If this is what happened, BP’s carelessness and complacency have inflicted a heavy toll on the Gulf, its inhabitants, and the workers on the rig…"

http://www.uscg.mil/foia/docs/DWH/BPDWH.pdf

**************************************************************************

March 31, 2011, Times-Picayune – Process of combining allegations against BP

in the wake of last year’s oil spill begins with court filings.

Attorneys representing businesses, fishermen and residents claiming to be

physically or financially injured by the BP Deepwater Horizon oil spill

filed two documents in federal court in New Orleans this week laying out key

pieces of their legal strategy, including charges that BP and drilling

contractor Transocean conspired to defraud the Minerals Management Service

concerning the safety of drilling such a deep well, and that their clients

were injured by the use of dispersants.

http://www.nola.com/business/index.ssf/2011/03/process_of_combining_allegatio.html

*

BP cut corners in days before Deepwater Horizon blowout, resulting oil spill, documents show.

http://blog.al.com/live/2010/06/bp_cut_corners_in_days_before.html?utm_source=twitterfeed&utm_medium=twitter

*

Oil spill hearings: BP didn’t test mud prior to critical pipeline procedure, driller testifies | NOL

http://www.nola.com/news/gulf-oil-spill/index.ssf/2010/05/oil_spill_update.html

*

19th-century law may come into play in BP case

@HoustonFowler: FuelFix: 19th-century law may come into play in BP case http://t.co/rOEZgeF via @fuelfixblog #oilspill #hounews

*

Investigator Warned MMS in 2009 About Deepwater Gas Blowouts in Gulf of Mexico

http://solveclimate.com/news/20100524/investigator-warned-mms-2009-about-deepwater-gas-blowouts-gulf-mexico

*

April 19, 2011, Telegraph (UK) – BP: disasters and disputes

It may have been a rocky twelve months for BP, but the past six years haven’t been easy either. We take a look at some of the oil giant’s lows.

http://www.telegraph.co.uk/finance/newsbysector/energy/oilandgas/8450067/BP-disasters-and-disputes.html

*

April 26, 2011, Orlando Sentinel – Carnival sues BP, others over Gulf of Mexico oil spill

Carnival is seeking damages for "economic losses and damages" suffered as a result of the oil spill, according to court documents filed April 20 in the U.S. District Court Eastern District of Louisiana.

To establish its eligibility to seek damages, Carnival said in court papers that it serves ports in Florida, Alabama, Texas and Louisiana and uses the Gulf of Mexico to transport guests and ship crew to several ports worldwide.

http://www.orlandosentinel.com/news/local/fl-carnival-bp-damages-20110426,0,7138899.story?track=rss&utm_source=twitterfeed&utm_medium=twitter&utm_campaign=Feed%3A+orlandosentinel%2Fnews%2Flocal%2Flake+%28OrlandoSentinel.com%3A+Lake+County+News%29&utm_content=Google+Feedfetcher

*

April 28, 2011 – NRDCGulf: Louisiana Oystermen File Class Action Against BP http://tinyurl.com/6ld6p3w

*

*

Info compiled by Marlitta H. Perkins, 2011

#CorporatePersonhood #ChemicalsHeavyMetalsVOCsampPoisonousToxins #Bacteria #GulfofMexicoGOM #GulfCoast #EnivironmentalConcern #GreedampCorruption #Toxic #Pollution #Vibrio

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