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

Filing 151

UNOPPOSED MOTION AND BRIEF for extension of time to file reply to Plaintiff's Response to Motion for Summary Judgment by intervenor parties Michigan Department of Environmental Quality, Michigan Department of History, Arts and Libraries; (Attachments: # 1 Proposed Order)(Reinwasser, Louis) Modified text on 2/13/2009 (gjf).

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, her tackle, apparel, appurtenances, cargo, etc. located within a circle having a radius of 3.5 statute miles, whose center point is at coordinates 45° 32.8 North latitude and 86° 41.5 West longitude, In Rem Defendant, v. STATE OF MICHIGAN DEPARTMENT OF HISTORY, ARTS, AND LIBRARIES AND MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY, Intervenors. _____________________________________________________________________________/ INTERVENORS' UNOPPOSED MOTION AND BRIEF FOR 14 DAY ENLARGEMENT OF TIME TO REPLY TO PLAINTIFF'S RESPONSE TO MOTION FOR SUMMARY JUDGMENT Intervenors State of Michigan Department of History, Arts, and Libraries and Michigan Department of Environmental Quality, by counsel, respectfully move the Court to enlarge their time for filing their reply to the Plaintiff's Response to Intervenors' Motion for Summary ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Civil Action No. 1:04-CV-375 HON. ROBERT HOLMES BELL

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Judgment from February 18, 2009 through and including March 4, 2009. The extension is necessitated in part by the fact that Intervenors did not receive until February 12, 2009, copies of declarations and other documents filed under seal that were included in Plaintiff's response to the motion for summary judgment. Plaintiff has consented to this Motion.

Respectfully submitted, Michael A. Cox Attorney General /s/ Louis B. Reinwasser (P37757) Assistant Attorney General Environment, Natural Resources and Agriculture Division P.O. Box 30755 Lansing, MI 48909 517/373-7540 Email: [e-mail] Dated: February 12, 2009 CERTIFICATE OF SERVICE I hereby certify that on February 12, 2009, I electronically filed the foregoing paper with the Clerk of the Court using the ECF system which will send notification of such filing to the counsel. /s/ Louis B. Reinwasser Louis B. Reinwasser (P37757) Assistant Attorney General Environment, Natural Resources and Agriculture Division P.O. Box 30755 Lansing, MI 48909 517/373-7540 Email: [e-mail]

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