IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

__________________________________________

)

UNITED STATES OF AMERICA,	)

)	Supplemental Action to

Petitioner,	)	Case No. 1:05CV02041

)	Judge: Emmet G. Sullivan

v.	)	Deck Type: Antitrust

)	Filed: November 26, 2007

)

CAL DIVE INTERNATIONAL, INC., and	)

HELIX ENERGY SOLUTIONS GROUP, INC.	)

)

Respondents.	)

)

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.	UNITED STATES OF AMERICA

HELIX ENERGY SOLUTIONS GROUP, INC.

_________/s/___________________	________/s/____________________

Daniel Wellington	Jennifer L. Cihon

Fulbright & Jaworski L.L.P.	U.S. Department of Justice

800 Pennsylvania Ave.	Antitrust Division

Washington, D.C. 20004-2615	325 7th St. N.W. Suite 500

Telephone: (202) 662-4574	Washington, D.C. 20530

Facsimile: (202) 662-4643	Telephone: (202) 307-3278

DWellington@fulbright.com	Facsimile: (202) 616-2441

Jennifer.Cihon@usdoj.gov