Home > Boards > US OTC > Miscellaneous >

UnderSea Recovery Corporation (UNDR)

UNDR RSS Feed
Add UNDR Price Alert      Hide Sticky   Hide Intro
Moderator: mick
Search This Board: 
Last Post: 5/18/2022 5:55:49 PM - Followers: 196 - Board type: Free - Posts Today: 0

 
On Twitter said, IF NOT CURRENT BY SEPT. DATE , 2021 THEN STOCK GOES TO EXPERT MARKET MAKER.

NOT GREY SHEETER !!!!!



yes, fool's gold ring !!!!! only thing so far no dilution 

07-10-2021
https://www.otcmarkets.com/stock/UNDR/security

[-chart]investorshub.advfn.com/uimage/uploads/2020/9/3/c[bxiCapture.JPG[/chart]



UNDR SECURITY DETAILS
Share Structure

Market Cap Market Cap 1,776,341
07/09/2021

Authorized Shares 1,100,000,000
12/03/2018

Outstanding Shares 657,904,177
12/03/2018

Restricted 121,707,225
12/03/2018

Unrestricted 536,196,952
12/03/2018

Held at DTC
Not Available

Float 391,696,952
12/31/2011

Par Value
0.001
 



UPDATED 05-04-2021 
https://www.undersearecovery.com/

https://www.otcmarkets.com/stock/UNDR/overview

Court Info:
https://www.pacermonitor.com/public/case/26762184/UnderSea_Recovery_Corporation_v_Madero_Holding,_SA_de_CV
 











 
 Emily1212 post# 21052 courtesy of Emily 0.000
Post #  of 21063 
 
04-13-2021 reading, reads o.k. needs some updating if allowed. case still alive.
as legals read updating needed.

i am sure UnderSea Recovery Corporation lawyers are well prepared.

[If UnderSea intends to tender exhibits during the hearing, electronic copies must be provided to the Court by 5:00 pm on Monday, April 13, 2021.]


Case 1:19-cv-00286-SDG Document 36 Filed 02/18/21

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

UNDERSEA RECOVERY CORPORATION, Plaintiff,
v.
MADERO HOLDING, S.A. de C.V., Defendant.

Civil Action No. 1:19-cv-00286-SDG

NOTICE SETTING EVIDENTIARY HEARING

Notice is hereby given that an evidentiary hearing is scheduled in
this matter regarding Plaintiff

UnderSea Recovery Corporation’s (UnderSea) motion for default judgment [ECF 34] on Wednesday, April 14, 2021 at 2:00 pm before the Honorable Steven D. Grimberg.

UnderSea must be prepared to discuss and present evidence establishing Defendant Madero Holdings, S.A. de C.V.’s (Madero’s) liability on its breach of contract claim and,
if appropriate, an award of damages.

This includes proof establishing a specific amount of damages for
(1) the alleged breach of contract;
(2) prejudgment interest pursuant to O.C.G.A. § 7-4-16;1. and
(3) attorneys’ fees and litigation expenses.

Due to the current public health emergency,
the hearing will be conducted via remote audio and video means.

The dial in instructions are as follows: https://ganduscourts.zoomgov.com/j/16 08599495; meeting ID: 160 859 9495; password: 190571; dial in number 646-828- 7666.

If UnderSea intends to tender exhibits during the hearing, electronic copies must be provided to the Court by 5:00 pm on Monday, April 13, 2021.

UnderSea is ORDERED to serve a copy of this Order via overnight
delivery on Madero at the two addresses listed by UnderSea in the Summonses [ECF 2; ECF 5] or to a more recent, known address.

SO ORDERED this the 18th day of February 2021.

Steven D. Grimberg United States District Court Judge

In the Complaint, UnderSea asserts a claim for prejudgment interest under O.C.G.A. § 7-4-16,
which provides a 1.5% interest rate.

In its motion for default judgment,
UnderSea calculates the alleged interest owed using O.C.G.A. § 7- 4-2, which permits a 7% rate.

UnderSea, however, cannot effectively amend its Complaint through a motion for default judgment to seek a different prejudgment interest rate—and increase its sought-after damages—than what it served on
Madero through international publication.

Thus, unless UnderSea files and serves Madero with an Amended Complaint, the Court will only consider the prejudgment interest rate expressed in O.C.G.A. § 7-4-16.

 

WEBI SITE STILL LIVE
https://www.undersearecovery.com/

UNDERSEA RECOVERY CORPORATION

2409 Chastain Dr.

Atlanta, GA 30342

www.undersearecovery.com404-826-1164info@unsr.com

 
DESCRIPTION
Utilizing experienced personnel and specialized vessels and equipment to engage in deep water search and recovery operations for historic shipwrecks.

https://www.otcmarkets.com/stock/UNDR/profile
https://www.otcmarkets.com/stock/UNDR/overview
https://www.otcmarkets.com/stock/UNDR/security

UNDR SECURITY DETAILS Share Structure
Market Cap Market Cap 2,236,874 2/18/2021

Authorized Shares..1,100,000,000
Outstanding Shares...657,904,177
Restricted..................121,707,225
Unrestricted...............536,196,952


5YR



Courtesy from Emily THANK YOU, NEW FILING 04-13-2021]YESTERDAY UnderSea Recovery Corporation (UNDR)'

NEW FILING YESTERDAY - IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

UNDERSEA RECOVERY
CORPORATION, Plaintiff,
v.
MADERO HOLDING, S.A. de C.V., Defendant.

Civil Action No.: 1:19-cv-00286-SDG

UNDERSEA RECOVERY CORPORATION’S SUPPLEMENTAL BRIEF FOR EVIDENTIARY HEARING

UnderSea Recovery Corp. (“UnderSea”), Plaintiff in the above action,
submits the following for the Court’s consideration during the evidentiary hearing scheduled for April 14, 2021.

I. EFFECT OF DEFAULT
Defendant Madero Holding, by its default, has admitted Plaintiff UnderSea Recovery Corporation’s well-pleaded allegations in the complaint. Maus v. Ennis 513 Fed. Appx. 872, 880, 2013 WL 1150140, 

at *6 (11th Cir. 2013) (“After a default is entered against a defendant, he is deemed to have admitted the plaintiffs’ well-pleaded factual allegations, and on appeal, he is barred from contesting those facts. 

Thus, ‘[a] default judgment is unassailable on the merits, 
but only so far as it is supported by well-pleaded allegations.’” (quoting Eagle Hosp. 

Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298, 1307 (11th Cir. 2009)). Because all well-pleaded allegations set forth in the Complaint are admitted, UnderSea has established 
(1) the existence of a valid contract binding Plaintiff and Madero, 

(2) Plaintiff’s performance under the contract, 

(3) Madero’s nonperformance under the contract, and 

(4) damages suffered by UnderSea as a result of Madero’s nonperformance.

II. PREJUDGMENT INTEREST
In the “Notice Setting Evidentiary Hearing” filed February 18, 2021, 
the Court expressed concern that in its complaint UnderSea seeks prejudgment interest of 1.5 percent pursuant to O.C.G.A. §7-4-16, 

but now is seeking prejudgment interest pursuant to O.C.G.A. §7-4-2 which provides for a 7 per cent rate.

O.C.G.A. §7-4-16 provides for a prejudgment interest rate of 1.5 percent per month 
(effectively, 18 per cent annually)3, 

but this statute applies only to past due debts arising from commercial accounts, not contracts. Noons v. Holiday Hospitality Franchising, Inc., 307 Ga. App. 351 (705 S.E. 2d 166) (2010).

Where a contract specified no rate of interest and complaint merely prayed for “interest” without specifying rate thereof, prejudgment interest only at the applicable “legal rate” of seven percent was authorized pursuant to O.C.G.A. § 7-4-2(a)(1). 

Gold Kist Peanuts v. Alberson, 178 Ga. App. 253 (342 S.E. 2d 694) (1986). As this
Court stated in SEC v. Price, 108 F. Supp. 3d 1342 (N.D. Ga. 2015):

Georgia law provides that a party recovering money damages is 
entitled
to prejudgment interest if the amount recovered is liquidated. 
O.C.G.A.
§7-4-15; Buchanan v. Bowman, 820 F.2d 359, 362 (11th Cir. 1987). 

A
debt is liquidated when it is certain how much is due and when it is due. Dalcor Mgmt. v. Sewer Rooter, Inc., 205 Ga. App. 681, 
(423 S.E.2d
419, 421 (Ga. Ct. App. 1992) 
… Where a contract does not specify an
interest rate, "pre-judgment interest accrues from the date of demand 
at
a rate of 7 percent per annum." 

Great Am. Ins. Co. v. Int'l Ins. Co., 753 3 Am. Aluminum Prods. Co. v. Binswanger Glass Co., 194 Ga. App. 703, Hn 6., (391 S.E. 2d) (1990) (citing Gen. Elec. Credit Corp. v.
Strickle Props., 861 F.2d 1532 (11th Cir. 1988)) ... 108 F.Supp.3d at 1348.

Because UnderSea discovered its error in demanding in the complaint 
the commercial open account rate of 1-1/2 per cent per month 
(18 percent per year), 
it is therefore conceding that it is only entitled to 7 percent interest, as provided in O.C.G.A. §7-4-2(a). See S. Water Techs. v. Kile, 224 Ga. App. 717, 720 (481 S.E. 2d 826) (1997).

Since Undersea is not seeking to increase its prejudgment interest damages, it should not be required to amend its complaint, 
since the Defendant could not be prejudiced by Plaintiff’s seeking a lesser amount of damages than sought in its compliant.

Nor, would the requirements of Fed. R. Civ. P. 54(c) be violated since the judgment would not exceed in amount, 
what is demanded in the pleadings, but would actually be less.

III. ATTORNEY’S FEES AND COSTS
UnderSea believes that it is clearly entitled to recover its costs 
of litigation and reasonable attorneys’ fees pursuant to O.C.G.A. § 13-6-1. It has been held that Case 1:19-cv-00286-SDG Document 39 Filed 04/13/21
attorneys’ fees of 15 percent pursuant to O.C.G.A. §13-1-11 are reasonable. 

“A plaintiff who is entitled to summary judgment on a document establishing 'evidence of indebtedness' within the meaning of O.C.G.A. 

§13-1-11(a) is also entitled to a judgment for attorneys' 
fees thereon." Dalcor Management v. Sewer Rooter, 
205 Ga. App. 681 (423 S.E. 2d 419) (1992) citing Woods v. Gen. Elec. Credit Auto Lease,
187 Ga. App. 57, 61(2), (369 S. E. 2d 334) (1988). 

An award of attorneys’ fees is justified under O.C.G.A. §13-6-11 
due to the evidence of record showing Defendant’s bad faith and its cause of unnecessary trouble and expense to Plaintiff. 

Examples of this include Madero's repeated verbal and written 
assurances that it would fulfill its contractual obligations.

4 A party's steadfast refusal to perform its
obligations under a contract can constitute bad faith. 

S. Water Techs, supra. at 720, citing Walther v. Multicraft Constr. Co., 205 Ga. App 815, 816 (2) (423 S.E. 2d 725) (1992).

UnderSea asks the Court to consider the exhibits attached hereto 
and made a part hereof, describing the legal fees and expenses
 UnderSea has incurred to date in bringing this action.

Exhibit A is the fee analysis from the firm of Greenberg Traurig LLP, listing its work on behalf of UnderSea from March 10, 2016 through March 13, 2020, 
reflecting attorneys' fees of $88,301.50 for 175.8 hours billed 
and paralegal fees of $5,558.50 for 132.7 hours billed.

Exhibit B is a statement from Sr. Carlos Diez, 
an attorney in Mexico retained by UnderSea for tasks related 
to completing service on Madero by publication. His bill of 
$5,000.00 was not stated in hours worked nor his hourly rate.

Exhibit C lists the legal fees and expenses incurred by UnderSea 
from its undersigned counsel from May 12, 2020 to date, 

and includes attorney's fees of $25,312.50 for 40.5 hours billed, paralegal fees of $225.00 for 2.6 hours, and a list of related costs.

The total costs of UnderSea's attorneys' fees to date totals $118,613.50, paralegal fees of $5,783.50 and expenses are $3,994.26.

Georgia contract law is the substantive law governing this action, 
and it requires that attorneys' fees and related costs be proved at trial. 

Cont'l. Cas. Co. v. HealthPrime, Inc., 2006 U.S. Dist. LEXIS 103116 (N.D. Ga., Oct.10, 2006). Thus, these exhibits are offered for the 
court to consider as damages. Alternatively, if the Court directs, 

UnderSea will also comply with the requirements of submitting a motion for its attorneys' fees and costs after judgment is entered, pursuant 
to Fed. R.
Civ. P. 54(d)(2) and LR 54.2.

IV. CONCLUSION

For the foregoing reasons UnderSea asks that the court enter a 
default judgment against Madero and award damages to Plaintiff to include the principal sum of $10,000,000.00, 
prejudgment interest of 7 percent, reasonable attorneys' fees, 
and costs of litigation.

Respectfully Submitted,
/s/ Donald C. English
DONALD C ENGLISH
Georgia Bar No. 248875
Attorney for Plaintiff

DONALD C. ENGLISH, LLC
3512 Knollhaven Drive, NE
Brookhaven, GA 30319
Phone: 404-783-0021
Email: english@cfaith.com


IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

UNDERSEA RECOVERY CORPORATION, Plaintiff,
v.
MADERO HOLDING, S.A. de C.V., Defendant.

CERTIFICATE OF SERVICE

I hereby certify that I have this date served the within and 
foregoing UnderSea's Supplemental Brief for Evidentiary Hearing 
with the Clerk of Court using CM/ECF system which will automatically send email notification of such filing to the parties and attorneys 
of record, who have entered appearance(s).

This 13th day of April, 2021.
/s/ Donald C English
DONALD C ENGLISH
Georgia Bar No. 248875
Attorney for Plaintiff


DONALD C. ENGLISH, LLC
3512 Knollhaven Drive, NE
Brookhaven, GA 30319
Phone: 404-783-0021
Email: english@cfaith.com




 

PER  IHUB  MGMT  

02-07-2021
DISCLAIMER:  ONLY FOR MICK
https://investorshub.advfn.com/boards/profilea.aspx?user=1012
*The Board Monitor and herewithin , are not licensed brokers and assume NO responsibility for actions,
investments,decisions, or messages posted on this forum.
 
CONTENT ON THIS FORUM SHOULD NOT BE CONSIDERED ADVISORY NOR SOLICITATION 
AUTHORS MAY HAVE BUYS OR SELLS  WITH THE COMPANIES MENTIONED IN TRADING POSTERS SHOULD DUE DILIGENT BUYING OR SELLING.
ALL POSTING SHOULD BE CONSIDERED FOR INFORMATION ONLY. WE DO NOT RECOMMEND ANYONE BUY OR SELL ANY SECURITIES POSTED HEREWITHIN.

ANY trade entered into risks the possibility of losing the funds invested.
• There are no guarantees when buying or selling any security.
Any



SURFKAST'S REMINDER
 

Warning!  This security is eligible for Unsolicited Quotes Only

This stock is not eligible for proprietary broker-dealer quotations. All quotes in this stock reflect unsolicited customer orders. Unsolicited-Only stocks have a higher risk of wider spreads, increased volatility, and price dislocations. Investors may have difficulty selling this stock. An initial review by a broker-dealer under SEC Rule15c2-11 is required for brokers to publish competing quotes and provide continuous market making.

Warning!  This security is traded on the Expert Market

The Expert MarketSM serves broker-dealer pricing and investor best execution needs. Quotations in Expert Market securities are restricted from public viewing. OTC Markets Group may designate securities for quoting on the Expert Market when it is not able to confirm that the company is making current information publicly available under SEC Rule 15c2-11, or when the security is otherwise restricted from public quoting. See additional information about the Expert Market here.

https://www.otcmarkets.com/stock/UNDR/overview


 

 



 

 
UNDR
Current Price
Volume:
Bid Ask Day's Range
  • 1D
  • 1M
  • 2M
  • 3M
  • 6M
  • 1Y
  • 2Y
  • 3Y
  • 5Y
PostSubject
#22288  Sticky Note 06-03-2021 ADDITIONAL STUFF,Wow judgement finally agreed on; $UNDR mick 06/04/21 07:35:56 PM
#23290   Not yet... still working on it. Emily1212 05/18/22 05:55:49 PM
#23289   They collect them millions yet? Guardian 05/18/22 10:55:14 AM
#23288   Let’s get to pennies Guardian 05/05/22 11:59:10 AM
#23287   Does Madero have $10mil? $UNDR JohnnyBlaze 05/02/22 11:54:14 AM
#23286   where? $UNDR JohnnyBlaze 05/02/22 11:50:42 AM
#23285   UnderSea Recovery Co (UNDR) mick 05/01/22 03:33:11 PM
#23284   Do tell!!!! Readyam 04/26/22 02:52:49 PM
#23283   New Filings.... Home Run 04/25/22 11:53:42 AM
#23282   It would show in the filings…..oh wait. jmhgolf 04/18/22 08:46:47 AM
#23281   Did they collect their judgment yet? Guardian 04/18/22 08:43:32 AM
#23280   UnderSea Recovery Co (UNDR) mick 03/12/22 03:46:52 PM
#23279   Are they getting their settlement? If so they Guardian 03/08/22 09:51:13 AM
#23278   Are they getting their settlement? If so they Guardian 03/08/22 09:51:11 AM
#23277   interesting emily UnderSea Recovery Co (UNDR) mick 02/06/22 04:49:20 PM
#23276   Long time no post…. I totally believe 2022 Emily1212 01/04/22 10:53:07 PM
#23274   What's the point Mick? Readyam 01/02/22 10:22:45 PM
#23273   https://www.otcmarkets.com/stock/UNDR mick 01/02/22 06:49:16 PM
#23272   When I talked with them, I was told Spartanfan1 12/30/21 10:20:20 AM
#23271   They have to file in the Mexican court surfkast 12/30/21 10:13:57 AM
#23270   This is a Bermuda Triangle of intrigue for Spartanfan1 12/29/21 03:31:24 PM
#23269  Restored This is a Bermuda Triangle. surfkast 12/27/21 01:35:14 PM
#23268   You are free to contact them too- if Spartanfan1 12/20/21 12:26:10 PM
#23267   That's all he could tell you? surfkast 12/20/21 12:25:06 PM
#23266   Thanks.....still a lotto for me...have looked for Maderno Readyam 12/20/21 11:55:31 AM
#23265   I did- he wasn’t able to tell me Spartanfan1 12/20/21 11:44:30 AM
#23264   So did you ask Spart whether they are Readyam 12/20/21 11:36:59 AM
#23263   UNDR is currently on the grey market, which Spartanfan1 12/20/21 10:32:54 AM
#23262   UNDR Share Structure (As of 2018) Spartanfan1 12/20/21 10:27:12 AM
#23261   This company has worked diligently for years- waiting Spartanfan1 12/20/21 10:18:56 AM
#23260   I contacted the company and got an immediate Spartanfan1 12/20/21 10:17:34 AM
#23259   yes thinking lots UnderSea Recovery Corporation (UNDR)' mick 12/14/21 01:34:04 PM
#23258   I'm hoping those 4,000,000 shares we bought by HomerRomer 12/12/21 06:32:39 PM
#23257   https://www.otcmarkets.com/stock/UNDR mick 12/11/21 07:18:19 PM
#23256   NO idea why this would be moving - Buckey 12/09/21 12:14:23 PM
#23255   Maybe the ghost of Mr. Madero appeared to Technocrack 12/08/21 01:53:03 PM
#23254   what is up? she's alive MEE3 12/08/21 01:47:08 PM
#23253   Anyone heard anything? Emily? Readyam 11/08/21 10:49:05 AM
#23252   Long Eyeofthetiger69 11/07/21 09:35:52 PM
#23251   Warning! This security is eligible for Unsolicited surfkast 11/07/21 07:41:11 PM
#23250   UnderSea Recovery Co (UNDR) mick 11/07/21 12:25:16 PM
#23249   Warning! This security is eligible for Unsolicited surfkast 11/01/21 11:36:12 AM
#23248   ….when they get their poop in order, .0185 Readyam 11/01/21 10:50:36 AM
#23246   Will do- you’ll be the first person that Spartanfan1 10/04/21 01:25:02 PM
#23245   Yes, let me know when they file their surfkast 10/04/21 01:20:44 PM
#23244   You are only copying what is written for Spartanfan1 10/04/21 01:12:16 PM
#23243   All prices reflect unsolicited customer orders and surfkast 10/04/21 01:08:36 PM
#23242   This is not a unique warning just to Spartanfan1 10/03/21 10:42:08 AM
#23241   Warning! Unsolicited Quotes Only surfkast 10/01/21 12:46:56 PM
#23240   Buy more load up today, don’t miss the Mic ll 10/01/21 11:37:02 AM
#23239   So…. From here we wait for the filings Readyam 09/29/21 10:22:26 AM
PostSubject
Consent Preferences