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

Filing 69

NOTICE by Odyssey Marine Exploration, Inc. re 44 Summons issued of Status of Service of Process on Kingdom of Spain (Thiel, Eric)

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Odyssey Marine Exploration, Inc. v. The Unidentified Shipwrecked Vessel Doc. 69 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION IN ADMIRALTY ODYSSEY MARINE EXPLORATION, INC. Plaintiff CIVIL ACTION Case No: 8:07-CV-00614- SDM- MAP 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. PLAINTIFF' S NOTICE OF STATUS OF SERVICE OF PROCESS ON KINGDOM OF SPAIN COMES NOW the Plaintiff, ODYSSEY MARINE EXPLORATION, by and through its undersigned attorneys, and states that it is filing similar, but not identical, filings in the following case numbers: 8:06-cv- 1685- 23MAP , 8:07-cv-614- 23MAP , and 8:07-cv-616- 23MAP. Plaintiff, Odyssey Marine Exploration, fies this Notice of Status of Service of Process on the Kingdom of Spain in the instant matter, and would respectfully state as follows: Plaintiff filed its Amended Complaint on August 7, 2007. Plaintiff has caused the Amended Complaint, its attachments, Motion for Protective Order Regarding Preliminary Site Assessment, Affidavit of Gregory P. Stemm in Relation to Plaintiff s Motion for Entry of a Protective Order Regarding Preliminary Site translated Assessment and Motion for Order Granting Preliminary Injunctive Relief to be into Spanish. Dockets.Justia.com The undersigned counsel for the Plaintiff has sought to complete service on the Claimant , Kingdom of Spain, pursuant to Fed. R.Civ. P. 4(j(i) by serving directed to the them via USM- Request for Service Abroad, Convention. Spanish Central Authority, pursuant the Hague At the present time, the Amended Complaint and the aforementioned motions and affidavit are in the hands of the Spanish Central Authority, and we are awaiting a Certificate from the Spanish Central Authority advising that service has been made on the Kingdom of Spain. Upon receipt of Certificate of Service, Plaintiff wil file proof of service pursuant to Fed. R.Civ. P. 4(L). Respectfully submitted Alle Florida Bar No. 0256803 Eric C. Thiel Florida Bar No. 016267 FOWLER WHITE BOGGS BANKER, P. P. O. Box 1438 Tampa , Florida 33601 813- 228- 7411 813- 229- 8313 - Facsimile avonsp fowlerwhite. com ethiel(cfowlerwhite. com Melinda J. MacConnel Odyssey Marine Exploration, Inc. 5215 West Laurel Street Tampa , FL 33607 (813) 876- 1776 , ext. 2240 Fax: (813) 830- 6609 mmacconnel shipwreck. net Attorneys for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that on DecemberZI , 2007, I electronically filed the foregoing with the Clerk of the Court by using the CM/ECF system which wil send a notice of electronic filing to James A. Goold, Covington & Burling LLP, 1201 Pennsylvania Ave. , NW, Washington DC 20004; and David C. Banker, Bush Ross P. , 220 S. Franklin Street, P. O. Box 3913 Tampa , FL 33601 Attorneys for Claimant. Alle on Splegelfeld Florida Bar No. 0256803 Eric C. Thiel Florida Bar No. 016267 FOWLER WHITE BOGGS BANKER , P. P. O. Box 1438 Tampa , Florida 33601 813- 228- 7411 813- 229- 8313 - Facsimile avonsp(cfowlerwhite. com ethiel((fowlerwhite. com Melinda J. MacConnel Odyssey Marine Exploration, Inc. 5215 West Laurel Street Tampa , FL 33607 (813) 876- 1776 , ext. 2240 Fax: (813) 830-6609 mmacconnel ((shipwreck. net Attorneys for Plaintiff 2428228vl

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