Free Answer to Crossclaim - District Court of Delaware - Delaware

Case 1:07-cv-00050-JJF Document 36 Filed 06/27/2007 Paget of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
DOMINION C ITRUS LIMITED, et al. :
Plaintiff, C.A No. 07-00050 (JJF)
v. :
MV BADRINATI-I, et al.
Defendant.
ANSWER OF DEFENDANTS SEATRADE REEFER CHARTERING NV, SEATRADE
GROUP NV, AND SEATRADE U.S.A., INC. TO CROSSCLAIMS OF ASHWATER
NAVIGATION C0., LTD.
Defendants, Seatrade Reefer Chartering NV, Seatrade Group NV, and Seatrade U.S.A.
(collectively, "Seatrade" or "Crossdefendants") answer the Crossclaim of
Defendant/Crossclaimant Ashwater Navigation Co., Ltd. ("Ashwater" or "Crossclaimant") as
follows:
l. Paragraph one of Ashwater’s Crossclaim pertains to answers to the
complaint and affirmative defenses that are not directed to Seatrade, and therefore no answer is
required. lf an answer is deemed necessary, then same is denied with strict proof thereof
demanded at time of trial.
2. Denied as stated. Seatrade Group NV was at all times material hereto
manager ofthe Seatrade Reefer Pool and in that capacity acted as disponent owner of vessels
entered in the pool. Seatrade Reefer Chartering NV at all times material hereto acted as general
agent for Seatrade Group NV. Seatrade U.S.A. at all times material hereto acted as local agent
for Seatrade in the United States.

Case 1:07-cv-00050-JJF Document 36 Filed 06/27/2007 Page 2 of 2
3. Paragraph 3 of Ashwater’s Crossclaim calls for a conclusion of law to
which no answer is required. If an answer is deemed necessary, then same is denied with strict
proof thereof demanded at time of trial.
4. Paragraph 4 of Ashwater’s Crossclaim calls for a conclusion of law to
which no answer is required. If an answer is deemed necessary, then same is denied with strict
proofthereof demanded at time oftrial.
5. Paragraph 5 of Ashwater’s Crossclaim calls for a conclusion of law to
which no answer is required. If an answer is deemed necessary, then same is denied with strict
proof thereof demanded at time of trial.
Wl-IEREFORE, Crossdefendants pray:
1 . That Plaintiffs’ Complaint be dismissed with prejudice.
2. That judgment be granted in favor of Crossdefendants and against
Crossclaimarits.
3. That Crossdefendants be granted such other relief as may be deemed just
and proper.
FOX ROTHSCHILD LLP
By: /s/ Sharon Oras Morgan
Sharon Oras Morgan, Esquire (# 4287)
Citizens Bank Center, Suite 1300
919 Market Street
Wilmington, Delaware 19801
Telephone: (302) 654-7444
Facsimile: (302) 656-8920
Attorneys for Defendants Seatrade Reefer
Chartering N K Seatrade Group NV and
Seatrade U.S.A., Inc.
Dated: June 27, 2007
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Case 1:07-cv-00050-JJF Document 36-2 Filed 06/27/2007 Page 1 of 1
CERTIFICATE OF SERVICE
I, Sharon Oras Morgan, Esquire, attorney for Defendants Seatrade Reefer Chartering NV,
Seatrade Group NV, and Seatrade USA., hereby certify that on June 27, 2007, two true and correct
copies of the foregoing Answer of Defendants Seatrude Reefer Churtering, N K, Seatrade Group Inc.
and Seotrade USA., Inc. to the Crossclaims of Ashwater Navigation Co., Ltd. , was served via First
Class Mail upon the following:
B.C. Goldstein, Esquire
615 West 18th Street
P.O. Box 1957
Wilmington, DE 19801
Steve Galatti, Esquire
Mattioni Limited
399 Market St, 2nd Fl.
Philadelphia, PA 19106
Frank DeGuillio
Palmer Biezup and Henderson
620 Chestnut St., Ste 956
Philadelphia, PA 19106
/s/ Sharon Oras Morgan
Sharon Oras Morgan
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