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

Filing 56

Third MOTION to extend time to File Completed Case Management Report (Joint Motion) by Odyssey Marine Exploration, Inc.. (Von Spiegelfeld, Allen)

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Odyssey Marine Exploration, Inc. v. The Unidentified, Shipwrecked Vessel or Vessels Doc. 56 Case 8:06-cv-01685-SDM-MAP Document 56 Filed 10/10/2007 Page 1 of 2 UNITED STATES DISTRICT COURT 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, in rem Defendant(s). _________________________________________/ THIRD JOINT MOTION FOR EXTENSION OF TIME TO FILE COMPLETED CASE MANAGEMENT REPORT COMES NOW, Plaintiff, ODYSSEY MARINE EXPLORATION, INC., and Claimant KINGDOM OF SPAIN, by and through undersigned counsel, and respectfully moves this Honorable Court to extend the time for filing the Case Management Report until October 30, 2007, and in support thereof would state: 1. This case involves many complicated nuances, including sovereign immunity, CIVIL ACTION Case No.: 8:06-CV-1685-T23-TBM maritime salvage, international treaties, and law of the sea. 2. The parties are preceding with the initial stages of pleadings, and as of yet, the case is not at issue. 3. In order to correctly prepare a Case Management Report, the parties agree that it is in the best interest of judicial economy to delay the filing of the Case Management Report until there is more certainty as to how the parties can and intend to proceed. Dockets.Justia.com Case 8:06-cv-01685-SDM-MAP Document 56 Filed 10/10/2007 Page 2 of 2 4. By granting an extension until October 30, 2007, the Court will provide the parties with the opportunity to prepare a meaningful Case Management Report. WHEREFORE, the parties respectfully moves this Honorable Court for an extension until October 30, 2007, to prepare the Case Management Report in the above mentioned matter. MEMORANDUM OF LAW The Court has the inherent power under Federal Rules of Civil Procedure 1.01 to extend time periods when it is the best interest of judicial economy and justice. In this case, it is in the best interest of judicial economy to extend the time until October 30, 2007, to allow the parties to have a more meaningful presentation to the Court. Respectfully submitted, s/ Allen von Spiegelfeld Allen von Spiegelfeld FBN 256803 avonsp@fowlerwhite.com Eric C. Thiel FBN 016267 ethiel@fowlerwhite.com FOWLER WHITE BOGGS BANKER P.A. P.O. Box 1438 Tampa, Florida 33601 (813) 228-7411 Facsimile: (813) 229-8313 Attorneys for Plaintiff s/ James A. Goold James A. Goold COVINGTON & BURLING LLP 1201 Pennsylvania Ave., NW Washington, DC 20004 (202) 662-5507 Facsimile: (202) 662-6291 E-mail: jgoold@cov.com - and David C. Banker Florida Bar No.: 352977 Bush Ross P.A. 220 S. Franklin Street P. O. Box 3913 Tampa, FL 33601-9313 (813) 224-9255 Facsimile: (813) 223-9620 E-mail: dbanker@bushross.com Attorneys for Claimant, Kingdom of Spain 2406456

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