Great Lakes Exploration Group LLC v. Unidentified Wrecked and (For Salvage-Right Purposes), Abandoned Sailing Vessel, The

Filing 104

MOTION for temporary restraining order and preliminary injunction by plaintiff Great Lakes Exploration Group LLC; (Attachments: # 1 Memorandum in support; # 2 Declaration in support of Steven J. Libert) (Robol, Richard) Modified on 8/28/2006 to add text (gjf).

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Great Lakes Exploration Group LLC v. Unidentified Wrecked and (For Sa...bandoned Sailing Vessel, The Doc. 10 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN Northern Division GREAT LAKES EXPLORATION GROUP LLC Plaintiff, v. ) ) ) ) Civil Action No. 1:04-CV-375 ) The Unidentified, Wrecked and (For Salvage- ) HON. ROBERT HOLMES BELL Right Purposes), Abandoned Sailing Vessel, etc. ) Defendant, et al. ) PLAINTIFF GREAT LAKES EXPLORATION'S APPLICATION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION P ursuant to Fed. R. Civ. P. 65, P laintiff Great Lakes Exploration, LLC, by counsel, respectfully moves the Court to grant a temporary restraining order and preliminary injunction restraining the Intervenors from utilizing information provided by Plaintiff regarding the precise location of the artifacts believed to be part of the Defendant shipwreck for (a) the purpose of taking, or attempting to take, actual possession o r custody of any such artifacts, and (2) for any purpose other than asserting and protecting their interests in this proceeding. In addition, Plaintiff respectfully renews its request that the Court forthwith issue a warrant for arrest of the Defendant and/or such portions of the Defendant as may be placed in the custody of the U.S. Marshal pursuant to Supplemental Rule C., Fed. R. Civ. Proc. In support of this Application, Great Lakes Exploration adopts the analysis and authorities in the attached Memorandum in Support. Dockets.Justia.com Respectfully submitted, GREAT LAKES EXPLORATION /s/ Richard T. Robol_______________ Richard T. Robol B 0064345 Attorney for Plaintiff ROBOL LAW OFFICE, LPA 555 City Park Avenue Columbus, Ohio 43215 Telephone: (614) 737-3739 Facsimile: (614) 737-3756 rrobol@robollaw.com CERTIFICATE OF SERVICE I hereby certify that on this 25th day of August, 2006, a copy of the foregoing was served by electronic mail via the Court's ECF system upon all counsel of record. /s/ Richard T. Robol ____________ Of Counsel 2

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