Odyssey Marine Exploration, Inc. v. The Unidentified, Shipwrecked Vessel or Vessels

Filing 26

Unopposed MOTION for James A. Goold to appear pro hac vice by Kingdom of Spain. (Banker, David) Motions referred to Magistrate Judge Thomas B. McCoun, III.

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Odyssey Marine Exploration, Inc. v. The Unidentified, Shipwrecked Vessel or Vessels Doc. 26 Case 8:06-cv-01685-SDM-TBM Document 26 Filed 06/01/2007 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION ODYSSEY MARINE EXPLORATION, INC. ) ) Plaintiff, ) ) ) v. ) ) THE UNIDENTIFIED, SHIPWRECKED VESSEL, ) OR VESSELS, their apparel, tackle, appurtenances ) and cargo located within center point coordinates: ) 49 25' N, 6 00' W; Radius: 5 nautical miles ) ) Defendant. ) / Case No. 8:06-cv-01685-SDM-TBM UNOPPOSED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE AND WRITTEN DESIGNATION AND CONSENT TO ACT James A. Goold, Esquire of the law firm of Covington & Burling, LLP, under Local Rule 2.02, Local Rules for the Middle District of Florida, moves for special admission to appear in this case pro hac vice as counsel for the Kingdom of Spain ("Spain"), and states as follows: 1. Local Rule 2.02 of the Local Rules for the Middle District of Florida provides: An attorney who is not a resident of Florida but who is a member in good standing of the bar of any District Court of the United States outside Florida may appear specially as counsel of record without formal or general admission; provided, however, such privilege is not abused by appearances in separate cases to such a degree as to constitute the maintenance of a regular practice of law in Florida; and provided further that whenever appearing as counsel by filing any pleading or paper in any case pending in this Court, a non-resident attorney shall file within ten (10) days a written designation and consent-to-act on the part of some member of the bar of this Court, resident in Florida, upon whom all notices and papers may be served and who will be responsible for the progress of the case, including the trial in default of the nonresident attorney. In addition to filing the written designation, the non-resident attorney shall comply with both the fee and e-mail Dockets.Justia.com Case 8:06-cv-01685-SDM-TBM Document 26 Filed 06/01/2007 Page 2 of 4 registration requirements of Rule 2.01(d), and the written designation shall certify the non-resident attorney's compliance. 2. Florida. 3. Mr. Goold is, and has been, a member in good standing of the bar of the United Mr. Goold resides in Washington, D.C., and is not a resident of the State of States District Court for the District of Columbia since 1991 (Bar No. 430315). Mr. Goold is also a member in good standing of the bars of the State of Illinois (Bar No. 0101972), and he has been admitted to practice before the United States Supreme Court, and before the United States First, Fourth, and District of Columbia Circuit Courts of Appeals. 4. David C. Banker, Esquire of the law firm of Bush Ross, P.A. ("Bush Ross"), a member in good standing of the bars of the State of Florida and of this Court, consents to act and accepts designation as local counsel for the Kingdom of Spain in this case. Accordingly, all notices given or required to be given in this case and all papers served in this case may be given to and served upon the Kingdom of Spain at the following address: David C. Banker, Esquire Bush Ross, P.A. Post Office Box 3913 Tampa, Florida 33601-3913 (813) 224-9255 (telephone) (813) 223-9620 (telecopy) dbanker@bushross.com 5. Mr. Goold has not previously requested pro hac vice admission before this Court and has not abused the privilege of appearance by special admission in other cases to such a degree as to constitute maintenance of the regular practice of law in Florida. Mr. Goold is simultaneously requesting appearance on behalf of the Kingdom of Spain in three cases brought by Odyssey Marine Exploration, Inc., because the three cases may concern shipwrecks and/or -2- Case 8:06-cv-01685-SDM-TBM Document 26 Filed 06/01/2007 Page 3 of 4 cargo belonging to or under charter by the Kingdom of Spain. The three cases in which Mr. Goold is seeking special admission are: Odyssey Marine Exploration, Inc. v. The Unidentified, Shipwrecked Vessel or Vessels, their apparel, tackle, appurtenances and cargo located within center point coordinates: 49 25' N, 6 00' W; Radius: 5 nautical miles, Case No. 8:06-cv-01685SDM-TBM; Odyssey Marine Exploration, Inc. v. The Unidentified, Shipwrecked Vessel, its apparel, tackle, appurtenances and cargo located within center point coordinates, in rem, Case No. 8:07-cv-00614-SCB-MAP; and Odyssey Marine Exploration, Inc. v. The Unidentified Shipwrecked, Vessel, its apparel, tackle, appurtenances and cargo located within center point coordinates, in rem, Case No. 8:07-cv-00616-JSM-MSS. 6. The Kingdom of Spain seeks special admission of Mr. Goold in these cases because Mr. Goold has represented the Kingdom of Spain in similar cases for many years, and Mr. Goold has a unique understanding of the Kingdom of Spain's claims regarding shipwrecks and cargo belonging to or under charter by the Kingdom of Spain. 7. Mr. Goold has submitted to the Clerk the required Special Admission Attorney Certification and will pay the fee required for special admission. 8. Counsel for the plaintiff does not object to Mr. Goold's request for special admission as counsel for the Kingdom of Spain. WHEREFORE, James A. Goold respectfully requests entry of an order granting his request to appear pro hac vice as counsel for the Kingdom of Spain in this case and such other relief as this Court deems just and proper. -3- Case 8:06-cv-01685-SDM-TBM Document 26 Filed 06/01/2007 Page 4 of 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 1st day of June, 2007, I electronically filed and sent by U.S. Mail the foregoing with the Clerk of Court by using the CM/ECF system. I further certify that I furnished by U.S. Mail delivery the foregoing and the notice of electronic filing to the Plaintiff c/o Allen K. Von Spiegelfeld and Eric Christopher Thiel, Fowler White Boggs & Banker, P.A., 501 E. Kennedy Blvd., Suite 1700, Tampa, Florida 33601. By: s/ James A. Goold James A. Goold District of Columbia Bar No. 430315 COVINGTON & BURLING, LLP 1201 Pennsylvania Avenue NW Washington, D.C. 20004 (202) 662-5507- Telephone (202) 662-6291- Facsimile jgoold@cov.com and By: s/ David C. Banker David C. Banker, FBN 352977 BUSH ROSS, P.A. P.O. Box 3913 Tampa, FL 33602-3913 (813) 224-9255- Telephone (813) 223-9620- Facsimile dbanker@bushross.com Attorneys for Kingdom of Spain -4-

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