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Chop spinach well and set aside. Melt butter in a large skillet over medium heat. Add shallots and cook, stirring frequently, until soft, about 4 minutes. Stir in flour and cook for 1 minute. Slowly add milk, stirring constantly. Stir in tarragon, salt, pepper, nutmeg and spinach and cook for 1 minute. Remove from heat and let cool. Sauce can be made up to 3 days ahead and refrigerated.
Preheat the broiler. Cover the bottom of a baking sheet with dried beans or rock salt. Carefully nestle rounded side of oyster shells in beans and place 1 oyster into each. If you have oyster liquor (juices) left over, let any grit settle to bottom and spoon liquor into spinach sauce. Stir sauce and spoon a generous 1 tablespoon onto each oyster. Sprinkle with cheese. Broil until tops are browned and sauce is heated through, about 4 minutes. Serve warm.
*Steamed from about 1 pound fresh, or a little less than a 16-ounce bag frozen chopped spinach cooked according to package directions.