Free Answer to Crossclaim - District Court of Delaware - Delaware

Case 1:07-cv-00484-JJF-LPS

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Filed 10/09/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE W C S T E E L INTERNATIONAL USA CORP. Plaintiff, v. MV DOBRUSH INREM. HER ENGINES. BOILERS, ETC., WESTERN BULK CARRIERS K.S., and COMMERCIAL FLEET OF DONBASS, Defendants. ANSWER OF WESTERN BULK CARRIERS U S . TO CROSSCLAIM OF DEFENDANTS MIV DOBRUSH, IN REM, AND COMMERCIAL FLEET OF DONBASS Defendant, Western Bulk Carriers WS incorrectly identified in the Complaint as Western Bulk Carriers AS., ("Western Bulk") by and through counsel answers the Cross Claim of Defendants MIV Dobrush, in rem, and Commercial Fleet of Donbass (Cross-Claimant) upon information and belief as follows: 1. Western Bulk incorporates by references its answers to paragraphs 1-9 of CIVIL ACTION No. 07-484 (JJF)

Plaintiffs Complaint as if hlly set forth herein. 2-3. The averments contained in paragraphs 2-3 call for a legal conclusion to which no

response is required.
4.

Western Bulk lacks information or knowledge sufficient to form a belief as to the

truth of the averments in this paragraph and are denied, and strict proof thereof is demanded at trial. WHEREFORE, Western Bulk prays:
1)

that the Cross-Claims of Cross-Claimant be dismissed; that judgment be entered in favor of Western Bulk against Plaintiff; and

2)

Case 1:07-cv-00484-JJF-LPS

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3)

for such other relief as this court deems equitable and just.

Dated: October 9,2007

FOX ROTHSCHILD, LLP

Sharon Oras Mornan / Fox Rothschild L ~ P 919 North Market Street, Suite 1300 Wilmington, DE 19899 (302) 622-4246 Attorney for Western Bulk Carriers L'S Of Counsel:
A. Robert Degen, Esquire Fox Rothschild LLP 2000 Market Street, Tenth Floor Philadelphia, PA 19103-3291 (215) 299-2000 - Phone (2 15) 299-2 150 - Fax

Case 1:07-cv-00484-JJF-LPS

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CERTIFICATE OF SERVICE
I, Sharon Oras Morgan, Esquire, hereby certify that I caused to be served two copies of the

foregoing Answer of Western Bulk Carriers U S to Cross Claim of Defendants MNDobrush,
in rem, und Commercial Fleet of Dorzbass thls 9th day of October, 2007 upon the following ~ounsel

of record via First Class U.S. Mail: Gary F. Seitz, Esquire Rawle & Henderson LLP 300 Delaware Avenue, Suite 1015 Wilmington, DE 19801 Lynne M Parker, Esquire Hollstein Keating Cattell John & Goldstein, P.C. 1201 North Orange Street, Suite 730 Wilmington, DE 19801 James F. Sweeney, Esquire Nicoletti Hornig & Sweeney Wall Street Plaza 88 Pine Street, 7thFloor New York, NY 10005