Free Declaration - District Court of Delaware - Delaware

Case 1 :07-cv-00197-JJF Document 5 Filed O4/06/2007 Page 1 of 2
lN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
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IN THE MATTER OF COMPLAINT OF CIVIL ACTION
WILMINGTON TUG, INC. AS OWNER OF IN ADMIRALTY
“LINDSEY,” A 70—FOOT 1989 TOWING VESSEL,
FOR EXONERATION FROM OR LHVIITATION OF N0.
LIABILITY
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DECLARATION OF VALUE
Michael B. McCauley, Esquire, hereby declares that he is a partner with the law firm of
Palmer Biezup & Henderson LLP, attomeys for the Petitioner herein and he is authorized to make this
Declaration on behalf of Wilmington Tug, Inc., as owner of the "L]NDSEY," a certain 70-foot 1989
crewboat built by Gladding—Heam Shipbuilding (hereinafter "the Vessel").
After the incident alleged in the Complaint, upon information and belief, the Vessel had a
fair market value of one-million two hundred thousand dollars and zero cents ($1,200,000.00), and
there was no freight then pending. This valuation is based upon the local market value of similar
vessels in similar condition at the time of the alleged incident.
Petitioner hereby undertakes to pay any costs that may be required in connection with this
`III limitation proceeding upon Order of this Honorable Court.
PBH; 189462.1
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Case 1 :07-cv-00197-JJF Document 5 Filed O4/06/2007 Page 2 of 2
Pursuant to 28 U.S.C. § 1746, I certify under penalty of perjury that the foregoing is true and
correct.
Executed on April 5, 2007.
Michael B. McCauley
psu. 189462.1
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