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

Filing 73

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

Doc. 73

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION IN ADMIRALTY

ODYSSEY MARINE EXPLORATION, INC.

Plaintiff
vs.

CIVIL ACTION
Case No. :
8:07- CV- 00616- SDM- MAP

THE UNIDENTIFIED, SHIPWRECKED VESSEL , its apparel, tackle, appurtenances and cargo located within center point
coordinates: (to be provided to the Court
under seal),

in rem

Defendant(s).

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, files 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
Relation to Plaintiffs

P.

Stemm in

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.
directed to the

4(j)(i) by serving 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).

Allen

on Spiegelfeld

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 fowlerwhite. com

Melinda J. MacConnel Odyssey Marine Exploration, Inc. 5215 West Laurel Street Tampa, FL 33607 (813) 876- 1776 , ext. 2240 Fax: [phone] mmacconnel shipwreck. net Attorneys for Plaintiff

CERTIFICATE OF SERVICE
, 2007, I electronically fied the foregoing I HEREBY CERTIFY that on Decembe 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 Attorneysfor Claimant.

Allen

on Spiegelfeld

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~fowlerwhite. com

Melinda J. MacConnel Odyssey Marine Exploration; Inc. 5215 West Laurel Street Tampa , FL 33607 (813) 876- 1776 , ext. 2240
Fax: [phone]

mmacconnel~shipwreck. net Attorneys for Plaintiff
2428231 vI