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

Filing 57

MOTION to amend/correct Complaint with certificate of service by plaintiff Great Lakes Exploration Group LLC; (Attachments: # 1 Attachment Brief in Support# 2 Exhibit A Second Amended Complaint) (Robol, Richard) Modified on 9/22/2005 to add text (gjf).

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

Doc. 57

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 ) )

PLAINTIFF'S MOTION TO FILE SECOND AMENDED COMPLAINT Pursuant to Fed. R. Civ. P. 15(a), Plaintiff Great Lakes Exploration respectfully moves the Court to file the Second Amended Complaint attached as Exhibit 1. The Second Amended Complaint (1) identifies the in rem Defendant by name, and (2) provides the location of the Defendant within an area of approximately 3 square nautical miles. In support of this Motion, Plaintiff adopts the analysis and authorities in its Memorandum filed herewith, and hereby made part of this Motion. Accordingly, Great Lakes Exploration prays the Court to file its Second Amended Complaint. Respectfully submitted, GREAT LAKES EXPLORATION GROUP LLC By:_//s// Richard T. Robol_______ Of Counsel Richard T. Robol (OH- 0064345) ROBOL & WINKLER LLC 555 City Park Avenue Columbus, Oh 43215 Telephone: [phone] Facsimile: [phone] [e-mail] ___//s// Roger Boer___________________ Of Counsel Roger Boer, Esq. 161 Ottawa Avenue N.W. Suite 600 Grand Rapids, MI 49503 Telephone. [phone] Facsimile: [phone]

ATTORNEYS FOR PLAINTIFFS

Dockets.Justia.com

CERTIFICATE OF SERVICE I hereby certify that on this 21st day of September, 2005, a copy of the foregoing was served by the Court's ECF system, via electronic mail upon all counsel of record. __//s// Richard T. Robol___________ Of Counsel

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