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

Filing 250

REQUEST for oral argument re 247 NOTICE - Statement of interest and brief as Amicus Curiae 231 Objection, 237 Response by Republic of Peru. (Shusta, Timothy) Modified on 10/5/2009 (AG).

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

Doc. 250

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION IN ADMIRALTY ODYSSEY MARINE EXPLORATION, INC., Plaintiff, v. THE UNIDENTIFIED, SHIPWRECKED VESSEL, If any, its apparel, tackle, appurtenances and cargo located within a five mile radius of the center point coordinates provided to the Court under seal, in rem Defendant, and THE KINGDOM OF SPAIN, THE REPUBLIC OF PERU, et al., Claimants. ____________________________________________/ PERU'S REQUEST FOR ORAL ARGUMENT ON OBJECTIONS TO REPORT AND RECOMMENDATION AND STATEMENT OF INTEREST OF THE UNITED STATES COMES NOW The Republic of Peru, by and through undersigned counsel and hereby requests, pursuant to Local Rule 3.01(j), Oral Argument on Objections to the Magistrate's Report and Recommendations dated June 3, 2009, the Responses to the Objections and the Statement of Interest filed by the United States. Counsel estimates that 30 minutes would be necessary for argument, allowing reservation of some time for rebuttal and respectfully suggests that plaintiff and each claimant or group of claimants be allowed 30 minutes for argument. Case No. 8:07-CV-00614-SDM-MAP

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Peru believes that in light of the numerous objections, the Statement of Interest by the United Stated, and the complex issues involved, oral argument would assist the court.

Respectfully Submitted, /s/ Mark Maney__________ Mark Maney Texas State Bar No. 12898200 Burford & Maney pc 700 Louisiana, Suite 4600 Houston, Texas 77002 713.237.1111 713.222.1475 (fax) [e-mail] Attorneys for the Republic of Peru and _/s/ Timothy P. Shusta______ Timothy P. Shusta FBN: 442305 Phelps Dunbar LLP 100 S. Ashley Drive Suite 1900 Tampa, FL 33602-5315 813-472-7550 813-472-7570 Fax [e-mail] Attorneys for the Republic of Peru Certificate of Service I HEREBY CERTIFY that a true and correct copy of the foregoing document was electronically filed with the Clerk of Court via CM/ECF system on October 2, 2009, which will generate and transmit Notices of Electronic Filing to all counsel of record and sent via email to Joseph A. Rodriguez-Menendez on October 2, 2009. _/s/ Timothy P. Shusta___ Timothy P. Shusta

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