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

Filing 60

AMENDED MOTION to amend/correct Complaint by plaintiff Great Lakes Exploration Group LLC; (Attachments: # 1 Affidavit Of Steve Libert in Support# 2 Attachment Brief in Support# 3 Exhibit 2nd Amended Complaint) (Robol, Richard)

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

Doc. 60

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 RENEWED 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 A. The Second Amended Complaint (1) identifies the in rem Defendant by name, (2) provides the location of the Defendant within an area of approximately 3 square nautical miles, and (3) provides the greatest degree of particularity practicable. In support of this Motion, Plaintiff adopts the analysis and authorities in its Memorandum and Affidavit of Steven Libert 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_______ ___//s// Roger Boer___________________ Of Counsel Of Counsel Richard T. Robol (OH- 0064345) Roger Boer, Esq. ROBOL & WINKLER LLC 161 Ottawa Avenue N.W. 555 City Park Avenue Suite 600 Columbus, Oh 43215 Grand Rapids, MI 49503 Telephone: [phone] Telephone. [phone] Facsimile: [phone] Facsimile: [phone] [e-mail] ATTORNEYS FOR PLAINTIFFS

Dockets.Justia.com

CERTIFICATION OF CONSULTATION AND DENIAL OF CONSENT Pursuant to L. Civ. R. 7.1(d), counsel for Plaintiff certifies that he has requested consent to the filing of the Second Amended Complaint by counsel for Intervenors, and counsel for Intervenors has refused to grant consent. __//s// Richard T. Robol___________ Of Counsel

CERTIFICATE OF SERVICE I hereby certify that on this 29th 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

2