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

Filing 130

SUPPLEMENT re 128 Joint Status Report by intervenor parties Michigan Department of Environmental Quality, Michigan Department of History, Arts and Libraries (Reinwasser, Louis)

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN NORTHERN DIVISION GREAT LAKES EXPLORATION GROUP LLC Plaintiff, v. The Unidentified, Wrecked and (For SalvageRight Purposes), Abandoned Sailing Vessel, etc. Defendant, et al. ) ) ) ) Civil Action No. 1:04-CV-375 ) ) HON. ROBERT HOLMES BELL ) ) )

PARTIES' SUPPLEMENTAL STATUS REPORT Plaintiff, Great Lakes Exploration Group, LLC and Intervenors State of Michigan Departments of History, Arts and Libraries and of Environmental Quality, by counsel, respectfully file the following Supplemental Status Report to address the current status of this proceeding, in particular, the filing of Intervenors' motion for summary judgment. 1) In the Status Report filed on November 5, 2008 (Docket #128), the parties

indicated that Intervenors expected to file a motion for summary judgment on or by December 1, 2008 asserting among other things, Intervenors' position that the Defendant is embedded in the soils of the State of Michigan, and therefore is owned by the State and not subject to federal admiralty jurisdiction. The parties also indicated that if for any reason Intervenors were unable to complete filing of their motion by that date, Plaintiff had agreed to extend the Intervenors' time to such date as may be reasonably required to complete filing of the motion.

2)

Intervenors have determined that they will need additional time to file their

motion for summary judgment and the parties have agreed that Intervenors will have until December 31, 2008 to file this motion.

Respectfully submitted,

GREAT LAKES EXPLORATION, LLC /s/ Richard T. Robol_______________ Richard T. Robol ROBOL LAW OFFICE, LLC 433 West Sixth Avenue Columbus, Ohio 43215 Telephone: [phone] Facsimile: [phone] [e-mail]

STATE OF MICHIGAN, DEPARTMENTS OF HISTORY, ARTS AND LIBRARY AND OF ENVIRONMENTAL QUALITY /s/Louis B. Reinwasser Louis B. Reinwasser Assistant Attorney General P.O. Box 30755 Lansing, Michigan 48909 [phone] [e-mail]

2004015720/Supplemental Status Report