Odyssey Marine Exploration, Inc. v. The Unidentified, Wrecked and Abandoned Sailing Vessel

Filing 23

Unopposed MOTION to extend time to file Verified Statement of Right or Interest by Ministry of Defence, United Kingdom. (Shusta, Timothy)

Odyssey Marine Exploration, Inc. v. The Unidentified, Wrecked and Abandoned Sailing Vessel

Doc. 23

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION IN ADMIRALTY ODYSSEY MARINE EXPLORATION, INC., Plaintiff. vs. THE UNIDENTIFIED, SHIPWRECKED VESSEL, its apparel, tackle, appurtenances and cargo located within a 5 mile radius of the center-point coordinates to be provided under seal at the Court's request, in rem, Defendant. / CASE NO. 8:08-cv-01045-RAL-MAP

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE CLAIM AND ANSWER COMES NOW Claimant, Ministry of Defence for the United Kingdom, by and through its undersigned counsel, pursuant to Rule 6(b)(1)(A) and requests an extension of time of 60 days, up to and including July 9, 2009 within which to file a Verified Statement of Right or Interest required by Supplemental Rule C(6)(a)(i)(a) and Local Rule 7.03(f)(1), followed by the usual 20 days to file the Answer required by Supplemental Rule C(6)(a)(iv) and Local Rule 7.03(f)(2), on the grounds that the parties are in current negotiations toward an agreement, which if successful will significantly reduce the issues to be resolved by this court.

TA.822014.1

Dockets.Justia.com

RULE 3.01(g) CERTIFICATE I HEREBY CERTIFY, that prior to filing this motion, I consulted with counsel for plaintiff, Odyssey Marine Exploration, Inc., regarding the relief requested, and plaintiff, through its counsel, has consented to granting the extension of time requested. WHEREFORE, Claimant, Ministry of Defence of the United Kingdom, requests entry of an Order extending the time for filing a Verified Statement of Right or Interest for 60 days, up to and including July 9, 2009. Respectfully submitted,

/s/ Timothy P. Shusta Timothy P. Shusta FBN: 442305 [e-mail] PHELPS DUNBAR LLP 100 South Ashley Drive · Suite 1900 Tampa, Florida 33602-5315 [phone] [phone] (FAX) Attorneys for Ministry of Defence, United Kingdom CERTIFICATE OF SERVICE I hereby certify that on March 7, 2009, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send a notice of electronic filing to the following counsel for plaintiff: Carl R. Nelson, Esq. Fowler White Boggs Banker, P.A. P.O. Box 1438 Tampa, FL 33601-1438 813- 228-7411, ext 1108 Melinda J. MacConnel, Esq. Odyssey Marine Exploration, Inc. 5215 West Laurel Street Tampa, FL 33607 813-876-1776, ext. 2240 /s/ Timothy P. Shusta Timothy P. Shusta

-2TA.822014.1