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

Filing 81

JOINT STATUS REPORT submitted for filing by plaintiff Great Lakes Exploration Group LLC (Robol, Richard)

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

Doc. 81

ROBOL LAW OFFICE, LPA
555 CITY PARK AVENUE COLUMBUS, OH 43215
Tel: [phone] Toll Free: 877/580-6859 Fax: [phone]
Writer's Direct Dial: 614/737-3739 Writer's E-Mail: [e-mail]

February 13, 2006 Susan Driscoll Bourque Case Manager U.S. District Court For the Western District of Michigan 602 Federal Courthouse Grand Rapids, Michigan 49503-2363 Great Lakes Exploration, etc. v. The Unidentified, etc., Case No.1:04-CV-375 Dear Ms. Bourque: The purpose of this letter is to provide a joint response on behalf of both Plaintiff and the Intervenors to your letter dated February 2, 2006. This letter is accordingly written on behalf of counsel for Plaintiff and for Intervenors. As noted in your letter, on October 25, 2005, the Court made an entry holding this matter in abeyance for the parties to consult regarding the terms and conditions of a cooperative investigation concerning whether the target was The Griffon. The parties have been working on the details of any such investigation, and they continue to be in serious discussions regarding the possibility of a cooperative investigation concerning the corroboration of the target as The Griffon. We expect to come to a firm understanding as to the feasibility of resolving the remaining issues, and to report to the Court, no later than April 17, 2006. The parties will continue to rely upon the abeyance entry while they pursue their discussions, and they would appreciate notice and an opportunity to be heard on any matters pertaining to the Court's entry. In the event that the current discussions are not successful, Plaintiff would plan to file a memorandum in opposition to the pending motion to dismiss, and the Intervenors would then file a reply.

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Letter to Susan Driscoll Bourque February 13, 2006 Page 2

We trust that this information responds to your letter. Please feel free to call should you have any further questions.

Respectfully, ROBOL LAW OFFICE, LPA By: _____________________________ Richard T. Robol RTR/cr

Cc:

James R. Piggush, Esq. Roger W. Boer, Esq.

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