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

Filing 66

MOTION for leave to file Response in Support of Motion for Leave to File Second Amended Complaint with certificate of service by plaintiff Great Lakes Exploration Group LLC; (Robol, Richard) Modified on 10/20/2005 to add text (gjf).

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

Doc. 66

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN Northern Division GREAT LAKES EXPLORATION GROUP LLC Plaintiff, v. 375 The Unidentified, Wrecked and (For SalvageRight Purposes), Abandoned Sailing Vessel, etc. Defendant, et al. ) ) ) )

Civil Action No. 1:04-CV-

) )HON. ROBERT HOLMES BELL ) )

PLAINTIFF GREAT LAKES EXPLORATION'S MOTION TO PERMIT FILING OF RESPONSE IN SUPPORT OF MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT Great Lakes Exploration respectfully moves the Court to permit filing of its Response in support of Great Lakes' Motion for Leave to File Second Amended Complaint. Filing of the Response will permit the Court the benefit of a full

consideration of the issues raised in Intervenors' Reply, and thereby assist the Court's deliberations. In further support of this Motion, Plaintiff adopts the analysis and

authorities set forth in the Response. Great Lakes Exploration has requested the consent of Intervenors to this Motion via e-mail but have not received consent. Respectfully submitted, GREAT LAKES EXPLORATION /s/ Richard T. Robol_______________ Richard T. Robol B 0064345 Attorney for Plaintiff ROBOL LAW OFFICE, LPA 555 City Park Avenue Columbus, Ohio 43215 Telephone: [phone] Facsimile: [phone] [e-mail]

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CERTIFICATE OF SERVICE I hereby certify that on this 19th day of October, 2005, a copy of the foregoing was served by electronic mail via the Court's ECF system upon all counsel of record. /s/ Richard T. Robol____________ Of Counsel

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