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

Filing 94

NOTICE of Additional Authority with certificate of service by plaintiff Great Lakes Exploration Group LLC (Robol, Richard) Modified on 7/7/2006 to add text (gjf, ).

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

Doc. 9

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN Northern Division GREAT LAKES EXPLORATION GROUP LLC Plaintiff, v. ) ) ) ) Civil Action No. 1:04-CV-375 ) The Unidentified, Wrecked and (For Salvage- ) HON. ROBERT HOLMES BELL Right Purposes), Abandoned Sailing Vessel, etc. ) Defendant, et al. ) PLAINTIFF GREAT LAKES EXPLORATION'S NOTICE OF ADDITIONAL AUTHORITY Plaintiff Great Lakes Exploration, LLC respectfully invites the Court's attention to the following additional authority, which was inadvertently omitted from Plaintiff's Memorandum in Opposition dated June 26, 2006: R.M.S. Titanic v. the Wrecked and Abandoned Vessel , 435 F.3d 521 (4th Cir. 2006). The recent authority from the U.S. Court of Appeals for the Fourth Circuit addresses the procedure for awarding salvor-in-possession status to a salvor who has agreed to act as a trustee for the public's interest in the scientific, historic and archaeological values of an historic shipwreck . See R.M.S. Titanic, 435 F.3d .at 537 ("the court may appoint the plaintiff to serve as salvor to further the public interest in the wreck's historical, archeological, or cultural aspects and to protect the site through injunctive relief, installing the salvor as its exclusive trustee so long as the salvor continues the operation. The court may, in addition to the traditional salvage remedies, also enter such orders as to the title and use of the property retrieved as will promote the historical, archeological, and cultural purposes of the salvage operation.")

Dockets.Justia.com

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]

CERTIFICATE OF SERVICE I hereby certify that on this 7th day of July, 2006, 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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