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
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 02-07-2021
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