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

Filing 17

STIPULATION and PROPOSED ORDER to extend deadlines by intervenor parties Michigan Department of Environmental Quality, Michigan Department of History, Arts and Libraries (Attachments: # 1 Proposed Order) (Piggush, James)

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

Doc. 17

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. and MICHIGAN DEPARTMENT OF HISTORY, ARTS AND LIBRARIES AND MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY, Intervening Defendants ______________________________________________________________________________ Richard Thomas Robol James R. Piggush Robol & Winkler LLC Assistant Attorney General 555 City Park Avenue Environment, Natural Resources, Columbus, OH 43215 and Agriculture Division 614/559-3846 P.O. Box 30755 Lansing, MI 48909 Roger W. Boer 517/373-7540 Roger W. Boer, LLC 161 Ottawa Avenue, NW Grand Rapids, MI 49503 616/235-3500 ______________________________________________________________________________ Civil Action No. 1:04-CV-375 HON. ROBERT HOLMES BELL

STIPULATION

Dockets.Justia.com

STIPULATION Whereas Plaintiff has served discovery requests to which responses are due on December 30, a state holiday, and Christmas holidays will occur during the previous week as well, and Whereas Plaintiff intends to refer to those responses in its response to Intervenors' Motion to Dismiss, which is currently due on December 18, 2004, although Intervenors do not acknowledge that those discovery requests have relevance to the pending motion, IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff and the Intervenors, through their respective counsel of record, to extend the following deadlines, as follows: Intervenors may have until January 13, 2005 to prepare their response to the pending discovery requests. Plaintiff may have until January 27 to complete their response to Intervenors' motion. The parties agree that the Court may enter the attached Order without further notice to any party. Dated: December 10, 2004 __/S/_____________________________ Richard Thomas Robol Robol & Winkler LLC Attorney for Great Lakes Exploration _/S/______________________________ Roger W. Boer Roger W. Boer, LLC Attorney for Great Lakes Exploration _/S/______________________________ James R. Piggush Assistant Attorney General Attorney for Intervenors

Dated: December 10, 2004

Dated: December 10, 2004

s:nrd/ac/cases/open/great lakes exp 04ag/stip re extension

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