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

Filing 8

MOTION to intervene (Piggush, James)

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

Doc. 8

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 ______________________________________________________________________________ MOTION TO INTERVENE Civil Action No. 1:04-CV-375 HON. ROBERT HOLMES BELL

Dockets.Justia.com

Now comes the Michigan Department of History, Arts and Libraries and the Michigan Department of Environmental Quality, by their attorneys Michael A. Cox, Attorney General and James R. Piggush, Assistant Attorney General, pursuant to Fed R. Civ. P24(a) and Fed. R. Civ. P Suppl E(2)(a) and move to intervene in this action for the limited purposes of filing the attached Motion to Dismiss for lack of jurisdiction and to defend the state's interest in and jurisdiction over its bottomlands and maritime cultural heritage for the reason that they are so situated that the disposition of this action may as a practical matter impair or impede their ability to protect the interests and the property of State of Michigan, and no present party before the court represents their interest, as more fully set forth in the brief filed in support of this motion. I have inquired of Plaintiff's attorneys and do not expect that this motion will be contested. Wherefore, the Michigan Department of History, Arts and Libraries, and the Michigan Department of Environmental Quality, request that their Motion to Intervene for the limited purposes of filing a Motion to Dismiss for lack of jurisdiction and to defend the state's interest in and jurisdiction over its bottomlands and maritime cultural heritage be granted. Respectfully submitted, Michael A. Cox Attorney General /s/ James R. Piggush (P29221) Assistant Attorney General Environment, Natural Resources, and Agriculture Division P.O. Box 30755 Lansing, MI 48909 517/373-7540 I hereby consent to electronic service in this case pursuant to Local Civil Rule 5.7 2

Dated October 14, 2004

s:nrd/ac/cases/open/great lakes exploration 04ag/motion to intervene

s:nrd/ac/cases/open/great lakes exploration 04ag/motion to intervene

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