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

Filing 131

STATUS REPORT on discovery and motions submitted for filing by plaintiff Great Lakes Exploration Group LLC (Attachments: # 1 Attachment - supplemental interrogatories to claimants, # 2 Attachment - supplemental requests for production of documents to claimants)(Robol, Richard) Modified text on 12/15/2008 (gjf).

Great Lakes Exploration Group LLC v. Unidentified Wrecked and (For Sa...bandoned Sailing Vessel, The

Doc. 13

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 Salvage Right Purposes), Abandoned Sailing Vessel, etc. Defendant, et al. ) ) ) ) Civil Action No. 1:04-CV-375 ) ) HON. ROBERT HOLMES BELL ) )

PLAINTIFF GREAT LAKES EXPLORATION'S S TATUS REPORT ON PLAINTIFF'S DISCOVERY AND MOTIONS P laintiff Great Lakes Exploration, LLC, by counsel, respectfully files this Status Report on Discovery and Motions. 1. On or about November 13, 2008 , Plaintiff served the attached discovery on

Claimants. 2. Answers to the discovery are needed for three separate purposes: (1) to assist

Plaintiff in opposing the Claimants' proposed motion for summary judgment; (2) to assist Plaintiff in conducting further discovery to oppose the proposed motion (including depositions, requests for admissions, supplementary interrogatories and supplementary requests for production); and (3) to allow Plaintiff to satisfy its obligations under Fed. R. Civ. P. 11 with respect to filing one or more motions of its own. 3. Claimants have requested an enlargement of time to respond to the pending Plaintiff has agreed to this enlargement, consistent with the spirit of

discovery.

cooperation among counsel which is a key element of federal discovery practice and procedure.

Dockets.Justia.com

4.

The condition precedent of Plaintiff's agreement to an enlargement has been the

Claimants ' agreement that the enlargement does not waive any of Plaintiff's rights or remedies as t o any matter in this proceeding or reflect any lack of due diligence by Plaintiff. Claimants have agreed to this condition. 5. Plaintiff expects to file its motion within 14 days, more or less, after it has

received full and complete answers to its pending discovery. Respectfully submitted, /s/ Richard T. Robol Richard T. Robol (0064345) ROBOL LAW OFFICE, LLC 433 West Sixth Avenue Columbus, Ohio 43201 [phone] [phone] (Facsimile) Attorneys for Plaintiff Great Lakes Exploration, LLC

CERTIFICATE OF SERVICE I hereby certify that on this 13 day of December, 2008, a copy of the foregoing was served by electronic mail upon counsel for Claimants and by regu lar mail, U.S., postage prepaid. /s/ Richard T. Robol
th

2