Case: Revolution Wind, LLC v. Burgum

Revolution Wind, LLC v. Burgum, et. al.

Revolution Wind, LLC v. Burgum et al.

Revolution Wind v. Burgum

Revolution Wind v. Green Oceans

COMPLAINT against BUREAU OF OCEAN ENERGY MANAGEMENT, BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT, DOUGLAS J. BURGUM, Matthew Giacona, Kenneth Stevens, U.S. DEPARTMENT OF THE INTERIOR ( Filing fee $ 405 receipt number ADCDC-11932225) filed by REVOLUTION WIND, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Civil Cover Sheet, # 4 Summons, # 5 Summons, # 6 Summons, # 7 Summons, # 8 Summons, # 9 Summons, # 10 Summons, # 11 Summons)(Schneider, Janice) (Entered: 09/04/2025)

1 Exhibit A

View on RECAP

2 Exhibit B

View on RECAP

3 Civil Cover Sheet

View on PACER

4 Summons

View on RECAP

5 Summons

View on PACER

6 Summons

View on PACER

7 Summons

View on PACER

8 Summons

View on PACER

9 Summons

View on PACER

10 Summons

View on PACER

11 Summons

View on PACER

NOTICE OF RELATED CASE by REVOLUTION WIND, LLC. Case related to Case No. 1:24-cv-00141 and 1:23-cv-03513 and 1:23-cv-03515. (Schneider, Janice) (Entered: 09/04/2025)

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by REVOLUTION WIND, LLC (Schneider, Janice) (Entered: 09/04/2025)

NOTICE of Appearance by Stacey Lynn VanBelleghem on behalf of REVOLUTION WIND, LLC (VanBelleghem, Stacey) (Entered: 09/04/2025)

NOTICE of Appearance by Roman Martinez on behalf of REVOLUTION WIND, LLC (Martinez, Roman) (Entered: 09/04/2025)

NOTICE of Appearance by Devin M. O'Connor on behalf of REVOLUTION WIND, LLC (O'Connor, Devin) (Entered: 09/04/2025)

SUMMONS (8) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zhcn) (Entered: 09/04/2025)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 9/5/2025. Answer due for ALL FEDERAL DEFENDANTS by 11/4/2025. (Schneider, Janice) (Entered: 09/04/2025)

Case Assigned/Reassigned

Case Assigned to Judge Royce C. Lamberth. (zhcn)

MOTION for Preliminary Injunction and Stay Pending Review and Statement of Points and Authorities in Support by REVOLUTION WIND, LLC. (Attachments: # 1 Declaration of Melanie Gearon, # 2 Gearon Exhibit 1, # 3 Gearon Exhibit 2, # 4 Gearon Exhibit 3, # 5 Gearon Exhibit 4, # 6 Declaration of Paul Murphy, # 7 Text of Proposed Order)(Schneider, Janice). Added MOTION to Stay on 9/8/2025 (znmw). (Entered: 09/05/2025)

1 Declaration of Melanie Gearon

View on RECAP

2 Gearon Exhibit 1

View on RECAP

3 Gearon Exhibit 2

View on RECAP

4 Gearon Exhibit 3

View on RECAP

5 Gearon Exhibit 4

View on RECAP

6 Declaration of Paul Murphy

View on RECAP

7 Text of Proposed Order

View on RECAP

NOTICE of Appearance by Kristofor R. Swanson on behalf of BUREAU OF OCEAN ENERGY MANAGEMENT, BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT, DOUGLAS J. BURGUM, MATTHEW GIACONA, KENNETH STEVENS, UNITED STATES DEPARTMENT OF THE INTERIOR (Swanson, Kristofor) (Entered: 09/06/2025)

NOTICE of Appearance by Amanda Rudat on behalf of BUREAU OF OCEAN ENERGY MANAGEMENT, BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT, DOUGLAS J. BURGUM, MATTHEW GIACONA, KENNETH STEVENS, UNITED STATES DEPARTMENT OF THE INTERIOR (Rudat, Amanda) (Entered: 09/07/2025)

MOTION for Leave to File Amicus Brief by NORTH AMERICA'S BUILDING TRADES UNIONS. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Newman, Jonathan) (Entered: 09/11/2025)

1 Memorandum in Support

View on RECAP

2 Text of Proposed Order

View on PACER

NOTICE of Appearance by Jonathan David Newman on behalf of NORTH AMERICA'S BUILDING TRADES UNIONS (Newman, Jonathan) (Entered: 09/11/2025)

NOTICE of Appearance by Jacob James Demree on behalf of NORTH AMERICA'S BUILDING TRADES UNIONS (Demree, Jacob) (Entered: 09/11/2025)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Blake Andrew Phillips, Filing fee $ 100, receipt number ADCDC-11950301. Fee Status: Fee Paid. by NORTH AMERICA'S BUILDING TRADES UNIONS. (Attachments: # 1 Declaration Pro Hac Vice Declaration, # 2 Exhibit Certificate of Good Standing, # 3 Exhibit Proposed Order)(Demree, Jacob) (Entered: 09/11/2025)

MOTION to Intervene, MOTION for Extension of Time to File Response/Reply as to 9 MOTION for Preliminary Injunction and Stay Pending Review and Statement of Points and Authorities in Support MOTION to Stay by GREEN OCEANS. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4)(Marzulla, Roger) (Entered: 09/12/2025)

1 Memorandum in Support

View on Clearinghouse

2 Text of Proposed Order

View on PACER

3 Exhibit 1

View on PACER

4 Exhibit 2

View on PACER

5 Exhibit 3

View on PACER

6 Exhibit 4

View on PACER

Memorandum in opposition to re 9 MOTION for Preliminary Injunction and Stay Pending Review and Statement of Points and Authorities in Support MOTION to Stay filed by BUREAU OF OCEAN ENERGY MANAGEMENT, BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT, DOUGLAS J. BURGUM, MATTHEW GIACONA, KENNETH STEVENS, UNITED STATES DEPARTMENT OF THE INTERIOR. (Attachments: # 1 Declaration Suess Declaration, # 2 Exhibit A to Suess Declaration, # 3 Exhibit B to Suess Declaration, # 4 Exhibit C to Suess Declaration, # 5 Exhibit D to Suess Declaration, # 6 Exhibit E to Suess Declaration, # 7 Exhibit F placer holder (sealed document), # 8 Exhibit G to Suess Declaration, # 9 Exhibit H to Suess Declaration, # 10 Exhibit I to Suess Declaration, # 11 Exhibit J to Suess Declaration, # 12 Orsted Article)(Swanson, Kristofor) (Entered: 09/12/2025)

1 Declaration Suess Declaration

View on RECAP

2 Exhibit A to Suess Declaration

View on RECAP

3 Exhibit B to Suess Declaration

View on PACER

4 Exhibit C to Suess Declaration

View on PACER

5 Exhibit D to Suess Declaration

View on PACER

6 Exhibit E to Suess Declaration

View on PACER

7 Exhibit F placer holder (sealed document)

View on PACER

8 Exhibit G to Suess Declaration

View on PACER

9 Exhibit H to Suess Declaration

View on PACER

10 Exhibit I to Suess Declaration

View on PACER

11 Exhibit J to Suess Declaration

View on PACER

12 Orsted Article

View on RECAP

SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by BUREAU OF OCEAN ENERGY MANAGEMENT, BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT, DOUGLAS J. BURGUM, MATTHEW GIACONA, KENNETH STEVENS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit F to Suess Declaration)(Swanson, Kristofor) (Entered: 09/12/2025)

ORDER granting 12 Motion for Leave to File Amicus Brief. Signed by Judge Royce C. Lamberth on 09/15/2025. (lcrcl1) (Entered: 09/15/2025)

AMICUS BRIEF by NORTH AMERICA'S BUILDING TRADES UNIONS. (znmw) (Main Document 21 replaced on 9/16/2025) (znmw). (Entered: 09/16/2025)

MINUTE ORDER: It is hereby ORDERED that the plaintiffs' opposition to the Motion to Intervene 16 shall be due no later than 5:00 p.m. on 9/16/2025. Signed by Judge Royce C. Lamberth on 09/15/2025. (lcrcl2)

Order

Order on Motion for Leave to Appear Pro Hac Vice

ORDER granting 15 Motion for Leave to Appear Pro Hac Vice. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions Signed by Judge Royce C. Lamberth on 09/15/2025.(lcrcl1)

MINUTE ORDER granting 15 Motion for Leave to Appear Pro Hac Vice. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions Signed by Judge Royce C. Lamberth on 09/15/2025.(lcrcl1) Modified on 9/16/2025 (zsmc).

ORDER granting 18 Sealed Motion for Leave to File Document Under Seal. It is hereby ordered that Exhibit F to the Suess Declaration shall be filed under seal. Signed by Judge Royce C. Lamberth on 09/15/2025. (lcrcl1) (Entered: 09/16/2025)

SEALED DOCUMENT (Exhibit F to Seuss Declaration) filed by BUREAU OF OCEAN ENERGY MANAGEMENT, BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT, DOUGLAS J. BURGUM, MATTHEW GIACONA, KENNETH STEVENS. re 17 Memorandum in Opposition. (This document is SEALED and only available to authorized persons.)(znmw) (Entered: 09/16/2025)

Memorandum in opposition to re 16 MOTION to Intervene MOTION for Extension of Time to File Response/Reply as to 9 MOTION for Preliminary Injunction and Stay Pending Review and Statement of Points and Authorities in Support MOTION to Stay filed by REVOLUTION WIND, LLC. (Attachments: # 1 Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Text of Proposed Order)(Schneider, Janice) (Entered: 09/16/2025)

1 Declaration

View on RECAP

2 Exhibit 1 to Declaration

View on RECAP

3 Exhibit 2 to Declaration

View on RECAP

4 Text of Proposed Order

View on RECAP

NOTICE of Appearance by Rachael Lynn Westmoreland on behalf of REVOLUTION WIND, LLC (Westmoreland, Rachael) (Entered: 09/16/2025)

NOTICE of Appearance by Blake Phillips on behalf of NORTH AMERICA'S BUILDING TRADES UNIONS (Phillips, Blake) (Entered: 09/16/2025)

Order

MINUTE ORDER: It is hereby ORDERED that Plaintiffs' reply to Defendants' opposition 17 to the Motion for Preliminary Injunction 9 is due by 5:00PM on 9/18/2025. It is further ORDERED that a hearing on the Motion for Preliminary Injunction will be held on 9/22/2025 at 11:00 AM in Courtroom 15. Signed by Judge Royce C. Lamberth on 09/16/2025.(lcrcl1)

REPLY to opposition to motion re 16 Motion to Intervene,, Motion for Extension of Time to File Response/Reply, filed by GREEN OCEANS. (Marzulla, Roger) (Entered: 09/17/2025)

ORDER granting 16 Motion to Intervene; granting 16 Motion for Extension of Time to File Response re 9 MOTION for Preliminary Injunction. Green Oceans' response is due by 9/17/2025. Signed by Judge Royce C. Lamberth on 09/17/2025. (lcrcl1) (Main Document 27 replaced on 9/18/2025) (zsmc). (Entered: 09/17/2025)

NOTICE of Appearance by Roger Joseph Marzulla on behalf of GREEN OCEANS (Marzulla, Roger) (Entered: 09/17/2025)

Memorandum in opposition to re 9 MOTION for Preliminary Injunction and Stay Pending Review and Statement of Points and Authorities in Support MOTION to Stay filed by GREEN OCEANS. (Attachments: # 1 Text of Proposed Order)(Marzulla, Roger) (Entered: 09/17/2025)

1 Text of Proposed Order

View on RECAP

REPLY to opposition to motion re 9 Motion for Preliminary Injunction,, Motion to Stay, filed by REVOLUTION WIND, LLC. (Attachments: # 1 Text of Amended Proposed Order)(Schneider, Janice) (Entered: 09/18/2025)

1 Text of Amended Proposed Order

View on RECAP

MOTION for Leave to File Supplemental Declarations by REVOLUTION WIND, LLC. (Attachments: # 1 Text of Proposed Order, # 2 Declaration of P. Murphy, # 3 Exhibit 1 to Murphy Declaration, # 4 Exhibit 2 to Murphy Declaration, # 5 Exhibit 3 to Murphy Declaration, # 6 Exhibit 4 to Murphy Declaration, # 7 Exhibit 5 to Murphy Declaration, # 8 Exhibit 6 to Murphy Declaration, # 9 Declaration of M. Gearon, # 10 Exhibit 1 to Gearon Declaration, # 11 Exhibit 2 to Gearon Declaration, # 12 Exhibit 3 to Gearon Declaration, # 13 Exhibit 4 to Gearon Declaration, # 14 Declaration of E. LeBlanc, # 15 Exhibit 1 to LeBlanc Declaration, # 16 Exhibit 2 to LeBlanc Declaration, # 17 Exhibit 3 to LeBlanc Declaration, # 18 Exhibit 4 to LeBlanc Declaration, # 19 Exhibit 5 to LeBlanc Declaration, # 20 Exhibit 6 to LeBlanc Declaration, # 21 Exhibit 7 to LeBlanc Declaration)(Schneider, Janice) (Entered: 09/18/2025)

1 Text of Proposed Order

View on RECAP

2 Declaration of P. Murphy

View on RECAP

3 Exhibit 1 to Murphy Declaration

View on RECAP

4 Exhibit 2 to Murphy Declaration

View on RECAP

5 Exhibit 3 to Murphy Declaration

View on RECAP

6 Exhibit 4 to Murphy Declaration

View on RECAP

7 Exhibit 5 to Murphy Declaration

View on RECAP

8 Exhibit 6 to Murphy Declaration

View on RECAP

9 Declaration of M. Gearon

View on RECAP

10 Exhibit 1 to Gearon Declaration

View on PACER

11 Exhibit 2 to Gearon Declaration

View on PACER

12 Exhibit 3 to Gearon Declaration

View on PACER

13 Exhibit 4 to Gearon Declaration

View on PACER

14 Declaration of E. LeBlanc

View on RECAP

15 Exhibit 1 to LeBlanc Declaration

View on PACER

16 Exhibit 2 to LeBlanc Declaration

View on PACER

17 Exhibit 3 to LeBlanc Declaration

View on PACER

18 Exhibit 4 to LeBlanc Declaration

View on PACER

19 Exhibit 5 to LeBlanc Declaration

View on PACER

20 Exhibit 6 to LeBlanc Declaration

View on PACER

21 Exhibit 7 to LeBlanc Declaration

View on PACER

SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by REVOLUTION WIND, LLC (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 2, # 2 Exhibit 3, # 3 Exhibit 5, # 4 Exhibit 6, # 5 Text of Proposed Order)(Schneider, Janice) (Entered: 09/18/2025)

ORDER granting 31 Motion for Leave to File Supplemental Declarations. Signed by Judge Royce C. Lamberth on 9/18/2025. (lcrcl1) (Entered: 09/18/2025)

ORDER granting 32 Sealed Motion for Leave to File Document Under Seal. It is hereby ORDERED that Exhibits 2, 3, 5, and 6 to the Rebuttal Declaration of Paul Murphy shall be filed under seal. Signed by Judge Royce C. Lamberth on 09/18/2025. (lcrcl1) (Entered: 09/18/2025)

DECLARATIONS (Rebuttal) by REVOLUTION WIND, LLC re 30 Reply to opposition to Motion. (Attachments: # 1 Declaration, # 2 Declaration)(znmw) (Entered: 09/25/2025)

1 Declaration

View on RECAP

2 Declaration

View on RECAP

SEALED DOCUMENT (Exhibits) filed by REVOLUTION WIND, LLC. re 37 Declaration. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 3, # 2 Exhibit 5, # 3 Exhibit 6)(znmw) (Entered: 09/25/2025)

MINUTE ORDER: The court will provide access for the public to telephonically attend the hearing scheduled for September 22, 2025, at 11:00 AM. The hearing can be accessed by dialing the Toll-Free Number: 833-990-9400 (Meeting ID: 720718696). It is hereby ORDERED that the attendees using the public access telephone line shall adhere to the following: persons remotely accessing court proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting any court proceedings (including those held by telephone or videoconference). Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the presiding Judge. So Ordered. Signed by Judge Royce C. Lamberth on September 19, 2025. (smc)

Order

NOTICE of Appearance by Peter Martin Torstensen, Jr on behalf of BUREAU OF OCEAN ENERGY MANAGEMENT, BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT, DOUGLAS J. BURGUM, MATTHEW GIACONA, KENNETH STEVENS, UNITED STATES DEPARTMENT OF THE INTERIOR (Torstensen, Peter) (Entered: 09/20/2025)

ORDER granting 9 Motion for Preliminary Injunction and Stay Pending Review. Upon consideration of all papers and evidence submitted in support of and in opposition to the Motion, and for the reasons stated on the record in open court, it is hereby ORDERED that the August 22 Stop Work Order is stayed pending review, and it is further ORDERED that the Defendants are enjoined from enforcing the Stop Work Order until such time as the Court orders otherwise. Signed by Judge Royce C. Lamberth on 9/22/2025.(lcrcl1) (Entered: 09/22/2025)

Minute Entry for Proceedings held before Judge Royce C. Lamberth: Motion Hearing held on 9/22/2025 re 9 MOTION for Preliminary Injunction and Stay Pending Review and Statement of Points and Authorities in Support filed by REVOLUTION WIND, LLC. For reasons set forth on the record, ECF 9 is HEREBY GRANTED. Order forthcoming via Chambers. (Court Reporter Lisa Moreira.) (zcll)

Motion Hearing AND Order on Motion for Preliminary Injunction

Order on Motion for Preliminary Injunction

TRANSCRIPT OF PRELIMINARY INJUNCTION HEARING before Judge Royce C. Lamberth held on September 22, 2025; Page Numbers: 1-53. Date of Issuance:September 26, 2025. Court Reporter/Transcriber Lisa A. Moreira, RDR, CRR, Telephone number (202) 354-3187, Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 10/17/2025. Redacted Transcript Deadline set for 10/27/2025. Release of Transcript Restriction set for 12/25/2025.(Moreira, Lisa) (Entered: 09/26/2025)