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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


UNITED STATES OF AMERICA,    

                  Petitioner,

                  v.

CAL DIVE INTERNATIONAL, INC., and
HELIX ENERGY SOLUTIONS GROUP, INC.   

                  Respondents.

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Supplemental Action to
Case No. 1:05CV02041
Judge: Emmet G. Sullivan
Deck Type: Antitrust
Filed: November 26, 2007

JOINT MOTION FOR ENTRY OF SETTLEMENT
AGREEMENT AND ORDER

The undersigned parties jointly move the Court for entry of the Settlement Agreement and Order. The parties urge the Court to grant this motion on the following grounds:

  1. The United States has filed a Petition for an Order to Show Cause Why Respondents Cal Dive International, Inc. and Helix Energy Solutions Group, Inc. Should Not Be Found in Civil Contempt ("Petition to Show Cause"). The Petition to Show Cause alleges violations by the Respondents of the Final Judgment and of the Hold Separate Stipulation and Order entered in United States v. Cal Dive International, Inc., et al., Civil Action No. 1:05CV02041. The United States also has filed a proposed Settlement Agreement and Order that settles the claims of the United States against Respondents;

  2. In the Stipulation, also filed on November 26, 2007, the parties consented to the Court's entry of the Settlement Agreement and Order, without further notice to any party or other proceedings; and

  3. The Settlement Agreement and Order constitutes a full settlement and release of the claims of the United States against Respondents, as defined in Paragraphs 2 and 3 of the Petition to Show Cause, arising from the violations of the Final Judgment and Hold Separate Stipulation and Order alleged in the Petition to Show Cause.

Dated: November 8, 2007

CAL DIVE INTERNATIONAL, INC.
HELIX ENERGY SOLUTIONS GROUP, INC.

_______________/s/________________
Daniel Wellington
Fulbright & Jaworski L.L.P.
800 Pennsylvania Ave.
Washington, D.C. 20004-2615
Telephone: (202) 662-4574
Facsimile: (202) 662-4643
DWellington@fulbright.com

UNITED STATES OF AMERICA


_______________/s/________________
Jennifer L. Cihon
U.S. Department of Justice
Antitrust Division
325 7th St. N.W. Suite 500
Washington, D.C. 20530
Telephone: (202) 307-3278
Facsimile: (202) 616-2441
Jennifer.Cihon@usdoj.gov