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

Filing 8

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

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Odyssey Marine Exploration, Inc. v. The Unidentified Shipwrecked Vessel Doc. 8 Att. 1 Case 8:07-cv-00616-JSM-MSS Document 8-2 Filed 04/13/2007 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 vs. CIVIL ACTION Case No. : 8:07- CV- 00616- JSM- MSS THE UNIDENTIFIED , SHIPWRECKED VESSEL , its apparel, tackle appurtenances and cargo located within center point coordinates: (to be provided to the Court under seal) II relli 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 Marshal' s Service, Marshal for this District , and the U. S. from any and liability and responsibility for the care and custody of the Unidentified Shipwrecked Vessel, its apparel , tackle, appurtenances and cargo located within center point coordinates provided the Court under seal , 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 8:07-cv-00616-JSM-MSS Document 8-2 Filed 04/13/2007 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 13th day of April , 2007 , at Tampa, Florida. Allen von Spieg eld Florida Bar No. 256803 avonsp(tfow l erwhi te. com FOWLER WHITE BOGGS BANKER , P. P. O. Box 1438 Tampa , Florida 33601 (813) 228-7411 (813) 229- 8313 - Facsimile Attorneys for Plaintiff

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