ExxonMobil Oil Corporation, et al. v. Mars Oil Pipeline Company, LLC, et al.

CourtDistrict Court, E.D. Louisiana
DecidedFebruary 4, 2026
Docket2:25-cv-02001
StatusUnknown

This text of ExxonMobil Oil Corporation, et al. v. Mars Oil Pipeline Company, LLC, et al. (ExxonMobil Oil Corporation, et al. v. Mars Oil Pipeline Company, LLC, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ExxonMobil Oil Corporation, et al. v. Mars Oil Pipeline Company, LLC, et al., (E.D. La. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA EXXONMOBIL OIL * CIVIL ACTION CORPORATION, ET AL. * NO. 25-2001 VERSUS * SECTION “G” (2) MARS OIL PIPELINE COMPANY, LLC, ET AL. *

ORDER AND REASONS

Pending before me is a Motion for Leave to File First Amended Complaint by Plaintiffs ExxonMobil Oil Corporation and Exxon Mobil Corporation. ECF No. 54. Defendants Shell Pipeline Company, LP, Mars Oil Pipeline Company LLC, Amberjack Pipeline Company, and LOCAP LLC timely filed Opposition Memoranda. ECF Nos. 56, 57. Plaintiffs filed a Reply Memorandum. ECF No. 63. No party requested oral argument in accordance with Local Rule 78.1, and the court agrees that oral argument is unnecessary. Having considered the record, the submissions and arguments of counsel, and the applicable law, Plaintiffs’ Motion for Leave to File First Amended Complaint is GRANTED for the reasons stated herein. I. BACKGROUND After receipt of allegedly contaminated crude oil, Plaintiffs ExxonMobil Oil Corporation and Exxon Mobil Corporation (together, “ExxonMobil”) filed suit asserting claims for redhibition, sale of unreasonably dangerous products in violation of the Louisiana Products Liability Act, negligence, and breach of contract against several defendants involved in the design and operation of the pipeline system that transported the crude oil. ECF No. 1. Defendants Shell Pipeline Company, LP (“SPLC”), Mars Oil Pipeline Company LLC (“Mars”), Amberjack Pipeline Company (“Amberjack”), Chevron U.S.A. Inc. (“Chevron”), TotalEnergies E&P USA, Inc. (“TEEP”) and LOCAP LLC (“LOCAP”) responded to the complaint with Rule 12(b)(6) motions to dismiss, filed on Tuesday, December 23, 2025. ECF Nos. 39, 40, 42, 43. After filing suit, Plaintiffs learned that Halliburton Company and/or Halliburton Energy Services, Inc. (not Transocean Ltd.) performed the relevant well completion services and Wood

Group USA, Inc. (not John Wood Group plc) was the proper entity to be named. ECF No. 54-2 ¶ 2. Plaintiffs then voluntarily dismissed without prejudice both Transocean, Ltd. and John Wood Group plc. ECF Nos. 36, 50. Invoking Rule 15(a)(2), Plaintiffs filed this Motion for Leave to File First Amended Complaint on Friday, January 16, 2026. ECF No. 54. Plaintiffs seek to add Halliburton Company, Halliburton Energy Services, Inc., and Wood Group USA, Inc. as defendants. ECF No. 54-2 ¶ 4. Although Plaintiffs do not assert any new claims against any existing party, they do amend certain allegations relating to previously asserted claims. Id. Defendants TEEP, SLB OneSubsea, Chevron, and LOOP LLC had no objection to the requested amendment, but SPLC, Mars, Amberjack, and LOCAP objected. ECF No. 56, 57. In their Opposition, SPLC, Mars, and Amberjack argue that Plaintiffs failed to mention the

pending motions to dismiss, and the new allegations are conclusory and thus futile, essentially re- urging the issues currently pending before Judge Brown in their Rule 12 motion. ECF No. 57 at 4-5, 7. They also argue that Plaintiff missed their deadline to amend pleadings and that Plaintiffs may raise the issues sought herein in their Reply to the pending motion to dismiss. Id. at 6, 8. They assert that allowing amendment would render their pending motion to dismiss moot and prejudice them by requiring the filing of a new motion. Id. at 8. LOCAP raises substantially similar arguments, relying primarily on futility and the assertion that Plaintiffs can raise the issues in their Reply Memorandum. ECF No. 56 at 3-6. In Reply, Plaintiffs argue that the proposed amendment adding additional defendants is certainly not futile and the proposed amendments clarifying the allegations are not futile for the reasons set forth in their Oppositions to the Motions to Dismiss. ECF No. 63 at 1-4. Plaintiffs further dispute the assertion that their motion was untimely as no deadline has been established.

Id. at 4-6. They then reiterate that there is not substantial reason to deny amendment under Rule 15. Id. at 5-7. II. APPLICABLE LAW Under Rule 15(a) of the Federal Rules of Civil Procedure, “[a] party may amend its pleading once as a matter of course” within 21 days of service or 21 days after service of a responsive pleading or motion under Rule 12(b), (e), or (f). FED. R. CIV. P. 15(a)(1)(A)-(B). In all other cases, a party may amend its pleading with the opposing party’s written consent or leave of court, which leave should be freely granted when justice so requires. FED. R. CIV. P. 15(a)(2). A. Plaintiffs’ Motion is Not Untimely Contrary to Defendants’ argument, Plaintiffs have not missed the deadline for seeking to

amend. Although Plaintiffs filed this motion 3 days after expiration of the 21-day period within which Plaintiffs were entitled to amend as of right under Rule 15(a)(1)(A), the court has not yet issued a Scheduling Order. Therefore, the court has not yet established a deadline for the filing of amended pleadings, which is typically thirty days after issuance of the Scheduling Order. While Plaintiffs’ 3-day delinquency precludes them from filing an Amended Complaint as of right (i.e., without court order or consent), the failure to seek leave within 21 days of the motion to dismiss does not render Plaintiffs’ motion untimely. And, as the court has not yet established a deadline for amending pleadings, Plaintiffs’ request for leave to amend is governed by Rule 15(a)(2) rather than the more stringent good cause requirements of Rule 16(b) that would apply had Plaintiffs sought to amend after expiration of the amendment deadline.1 B. Reply Memoranda Cannot Raise New Issues Defendants assert that leave to amend should not be granted because Plaintiffs may assert

these new facts in their Reply to the pending motions to dismiss. ECF No. 56 at 6; No. 57 at 4-5, 7. The scope of a reply memorandum, however, is limited to addressing issues raised in the opposition.2 Accordingly, a reply memorandum is not an appropriate avenue to raise new allegations or amend a complaint. C. Standard for Amendments Rule 15(a)(2) expressly states that the “court should freely give leave [to amend] when justice so requires.”3 The relevant inquiry thus requires the court to balance the difficult task of assuring a party a fair opportunity to present its claims and defenses while at the same time protecting the district court from being imposed upon by the presentation of theories seriatim.4

1 See S&W Enters., L.L.C. v. SouthTrust Bank of Ala., NA, 315 F.3d 533, 535–36 (5th Cir. 2003) (holding that Federal Rule of Civil Procedure 16(b) governs the amendment of pleadings after a scheduling order deadline has expired and only upon a showing of good cause will the more liberal standard of Rule 15(a) apply to the court’s decision to grant or deny leave). 2 Magnolia Island Plantation, L.L.C. v. Whittington, 29 F.4th 246, 251-52 (5th Cir. 2022) (“As a general matter, a district court is not required to address new legal issues raised only in a reply brief.” (citations omitted)); Little Tchefuncte River Ass’n v. Artesian Util. Co., 155 F. Supp. 3d 637, 657 (E.D. La. 2015) (Brown, J.) (“[A]rguments cannot be raised for the first time in a reply brief.” (quoting Benefit Recovery, Inc. v. Donelon, 521 F.3d 326, 329 (5th Cir. 2008))); J.I. ex rel. Interiano v. Jefferson Par. Sch. Bd., No. 23-1532, 2023 WL 8563034, at *6 n.5 (E.D. La. Dec. 11, 2023) (Guidry, J.) (quoting Iteld, Bernstein & Assocs., LLC v. Hanover Ins. Grp., No. 06-3418, 2009 WL 2496552, at *4 (E.D. La. Aug. 12, 2009) (Vance, J.) (citing United States v. Jackson, 426 F.3d 301

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Collins v. Morgan Stanley Dean Witter
224 F.3d 496 (Fifth Circuit, 2000)
Herrmann Holdings Ltd. v. Lucent Technologies Inc.
302 F.3d 552 (Fifth Circuit, 2002)
Mayeaux v. Louisiana Health Service & Indemnity Co.
376 F.3d 420 (Fifth Circuit, 2004)
Smith v. EMC Corporation
393 F.3d 590 (Fifth Circuit, 2004)
United States v. Jackson
426 F.3d 301 (Fifth Circuit, 2005)
Ferrer v. Chevron Corp.
484 F.3d 776 (Fifth Circuit, 2007)
Benefit Recovery, Inc. v. Donelon
521 F.3d 326 (Fifth Circuit, 2008)
St. Germain v. Howard
556 F.3d 261 (Fifth Circuit, 2009)
Gonzalez v. Kay
577 F.3d 600 (Fifth Circuit, 2009)
Campbell v. Emory Clinic
166 F.3d 1157 (Eleventh Circuit, 1999)
Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Tellabs, Inc. v. Makor Issues & Rights, Ltd.
551 U.S. 308 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Gentilello v. Rege
627 F.3d 540 (Fifth Circuit, 2010)
RANDALL D. WOLCOTT, MD, PA v. Sebelius
635 F.3d 757 (Fifth Circuit, 2011)
Gregory v. Mitchell
634 F.2d 199 (Fifth Circuit, 1981)

Cite This Page — Counsel Stack

Bluebook (online)
ExxonMobil Oil Corporation, et al. v. Mars Oil Pipeline Company, LLC, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/exxonmobil-oil-corporation-et-al-v-mars-oil-pipeline-company-llc-et-laed-2026.