On Oct. 22, Odyssey Marine Exploration filed replies to Spain's opposition to Odyssey's amended complaint, motion for protective order regarding Preliminary Site Assessment, and Preliminary Injunction. There are three arrested sites that I have called the Land's End, Black Swan, and Ancona. The various responses are much the same for each site but there are differences so I will post the responses for each site. If you had to choose, the Black Swan site would probably be the most important as this is the site where the recent treasure find was recovered and it is closest to Spain's territory.
In brief, Odyssey's replied that:
It's arrest of the vessel(s) were proper.
Odyssey's Amemded Complaint(s) met the pleading requirements of the rules.
The U.S. court has personal jurisdiction over Spain.
Spain does not have sovereign immunity.
Odyssey Marine also requests an Oral Argument in that:
1. Plaintiff believes that oral argument will be necessary to better assist this
Court in understanding the factual and legal issues related to the parties’ arguments in each
case of the three pending motions [Plaintiff’s Motion for Order Granting Preliminary
Injunctive Relief, Plaintiff’s Motion for Protective Order, and Claimant Kingdom of Spain’s Motion to Dismiss and for Other Relief.]
Plaintiff believes oral argument would particularly assist the Court in clarifying the different circumstances and facts regarding the three salvage actions currently before the Court.
From justia.com the Land's End response is here:
MEMORANDUM in opposition to Spain's Motion to dismiss
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2006cv01685/186117/59/0.html
REPLY to response to Spain's response to MOTION for protective order Regarding Preliminary Site Assessment
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2006cv01685/186117/60/0.html
REQUEST for oral argument concerning the MOTION for protective order Regarding Preliminary Site Assessment, and MOTION to dismiss Plaintiff's Amended Complaint and for Other Relief
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2006cv01685/186117/61/0.html
From justia.com the Black Swan response is here:
MEMORANDUM in opposition to Spain's Motion to dismiss
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2007cv00614/197978/53/0.html
REPLY to response to Spain's response to MOTION for protective order Regarding Preliminary Site Assessment
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2007cv00614/197978/54/0.html
REQUEST for oral argument concerning the MOTION for protective order Regarding Preliminary Site Assessment, and MOTION to dismiss Plaintiff's Amended Complaint and for Other Relief
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2007cv00614/197978/56/0.html
REPLY to Spain's response to MOTION for preliminary injunction
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2007cv00614/197978/57/0.html
From justia.com the Ancona response is here:
MEMORANDUM in opposition to Spain's Motion to dismiss
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2007cv00616/197307/58/0.html
REPLY to response to Spain's response to MOTION for protective order Regarding Preliminary Site Assessment
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2007cv00616/197307/59/0.html
REPLY to Spain's response to MOTION for preliminary injunction
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2007cv00616/197307/60/0.html
REQUEST for oral argument concerning the MOTION for protective order Regarding Preliminary Site Assessment, and MOTION to dismiss Plaintiff's Amended Complaint and for Other Relief
http://docs.justia.com/cases/federal/district-courts/florida/flmdce/8:2007cv00616/197307/61/0.html