Free Opening Brief in Support - District Court of Delaware - Delaware

Case 1 :06-cv-00016-GIVIS Document 3 Filed 01/O9/2006 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
IN THE MATTER OF THE COIVIPLAINT *
OF CLARY SHIPPING (Pte.) LTD.,
AS OWNER(S) AND/OR OW"NER(S) * Civil Action No.:
PRO HAC VICE OF THE MOTOR VESSEL
CLARY FOR EXONERATION FROM OR *
LIMITATION OF LIABILITY
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MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION
TO ACCEPT AD INTERIM STIPULATION F ORVALUE, AND FOR THE
ENTRY OF RESTRAIN IN G ORDER AND OIUDER FOR IS SUANCE OF NOTICE
Clary Shipping (Pte.) Ltd ("Clary Shipping") as Owners and/or Owners Pro Hoc Vice of
the motor vessel CLARY by their undersigned attorneys, hereby submits this Memorandum of
Points and Authorities in support of their Motion to Accept the Ad Interim Stipulation for Value
proffered by Clary Shipping, and to enter a Restraining Order and Order that Notice ofthe
commencement of this proceeding be issued, all as prayed for in the Complaint herein.
Points and Authorities
Rule F, Supplemental Rules of the Federal Rules of Civil Procedure for Certain
Admiralty and Maritime Claims.
/S/ Richard R. Wier, Ir.
Richard R. Wier, Jr. (#716)
Daniel W. Scialpi (#4146)
RICHARD R. WIER, JR., P.A.
1220 Market St., Suite 600
Wilmington, DE 19801
(302)888-3222
[email protected]
Attorneys for Clary Shipping (Pie.), cis Owner and
Owner Pro Hoc Vice of the Motor Vessel CLARY
Attorneys for Clary Shipping (Pte.) , as Owner
and/or Owner Pro Hoc Vice of the Motor Vessel
CLARY
Ran maui: ws/2006 11147 AM