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

Filing 4

MOTION to appoint custodian (substitute custodian) by Odyssey Marine Exploration, Inc.. (Attachments: # 1 Affidavit # 2 Consent and Indemnification Agreement for Appointment of Substitute Custodian)(Von Spiegelfeld, Allen)

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Odyssey Marine Exploration, Inc. v. The Unidentified, Shipwrecked Vessel or Vessels Doc. 4 Att. 2 Case 8:06-cv-01685-SDM-TBM Document 4-3 Filed 09/15/2006 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION IN ADMIRALTY ODYSSEY MARINE EXPLORATION, INC., Plaintiff CIVIL ACTION THE UNIDENTIFIED , SHIPWRECKED VESSEL OR VESSELS, their apparel , tackle, appurtenances and cargo located within center point coordinates: NO. 8:06-cv- 1685- T23- TBM 25' N, 6 00' W; Radius: 5 nautical miles in rem Defendant(s). CONSENT AND INDEMNIFICATION AGREEMENT FOR THE APPOINTMENT OF A SUBSTITUTE CUSTODIAN Plaintiff, Odyssey Marine Exploration , and Odyssey Marine Exploration , release the U. S. Inc. , Inc. , by and through its undersigned attorneys the proposed substitute custodian , hereby expressly and the U.S. Marshal' s Service, Marshal for this District , from any and all liability and responsibility for the care and custody of the Unidentified Shipwrecked Vessel , its apparel , tackle, appurtenances and cargo located at coordinates: 49 25' N , 6 00' W; Radius: 5 nautical miles, while in the hands of the substitute custodian , Odyssey Marine Exploration , Inc. Plaintiff and Substitute Custodian , Odyssey Marine Exploration , Inc. , also expressly agree to hold the U.S. Marshal for this District and the U.S. Marshal' s Service harmless from any and all claims whatsoever arising during the period of the substitute custodianship. Dockets.Justia.com Case 8:06-cv-01685-SDM-TBM Document 4-3 Filed 09/15/2006 Page 2 of 2 As counsel of record in this action , the undersigned attorney represents that he has been expressly authorized by the Plaintiff to sign this Consent and Indemnification Agreement for and on behalf of the Plaintiff. SIGNED this 15th day of September , 2006 , at Tampa, Florida. llen yon Spie Florida Bar No. 256803 avonsp(cfow lerwhite. com ged FOWLER WHITE BOGGS BANKER , P. P. O. Box 1438 Tampa , Florida 33601 (813) 228-7411 (813) 229- 8313 - Facsimile Attorneys for Plaintiff #2274523vl

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