Amicus Curiae Brief — Hellenic Lines Ltd. v. Rhoditis

Office-Sisri ¢ |

FIL Ej

SUPREME COURT, U. S.

* FEB 96 1970

JOHN F. DAVIS, CLERK

Suprens Court of the United States

- ; October Term, 1969

No. 661

HELLENIC LINES LIMITED '

a

7 * i,

_ Joun R. ‘SHENEMAN

Attorney for Amici Curiae

, Pineda Greek Chamber of Shipging

| ‘and

2 9 ‘ The Union of Greek Shipowners

2 coe bo ™ 19 Rector Street

Grab ener tp, eo New York, New York 10006

Epwin K. Rew |

- Georce D. Benes | 7

Of Counsel

7 and

UNIVERSAL CARGO CARRIERS, ING,,

Petitioners,

| v.

, Oy

ZACHARIAS RHODITIS, oni

Respondent.

AMICI CURIAE BRIEF IN SUPPORT OF PETITIONERS

TABLE OF CONTENTS

PAGE |

Statement of Interest of Amict Curtae oo... 1

Argument ab cs rex cca latoheca oe hssssic pape oh ui aaa a Apspseaeaa Mane 4

Conclusion cestacestessafeiaanivepatcaced Re iccighickpivinsees i eee ae |

Certificate of Servieo penne lnapalnteclanan ical agen tosey ioe 13 2

. ; } P

Exhibit: A. PRG ie ee Sp cckeeaeni Foner Ree acon la

ee Ma Reeiatetes nenweie Cone eee ies

| * TABLE OF AUTHORITIES

” Lauritzen v. Larsen (1953) 345 U.S. 571 ....:.4, 5, 6, 7, 8, 9,11

McCulloch y. Sociedade “Nacionale d. Marineros de

Brazil (1963) BE BA. TI Seckcicomncdoseninaomne ae

Nikitas Missos et al. v. Transpacific Cassiere — .

and Hellenic Lines, Ltd. (U.S.D. G. 8. D. N.Y.) .. 11 |

Romero -v. International. Terminal Operating Co.

(1959) 358 U.S. 354 ......... TREE aE Rp POR We 5°

Tjonaman v. A/S Glittre et al., 340 F'.2d'290 (2 CA.

1965) cert. den. 381 U.S. 925 (1965) reh. den. 382.

: U.S, 873 (1965) ........... acs Sewech Anaaneiek Grtacia aethanoaimaaaanants a

Tsakonites v. Transpacific Carriers Cotpveaitinn —_—...

F.2d 426, 2 Cir. 1966, cert. denied 386 U.S. 1007 10°

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AMICI CURIAE BRIEF IN SUPPORT OF PETIT IONERS

IN THE a

or Court of the United States

October — 1969

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No. 661

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. °

HELLENIC LINES LIMITED.

-and°

UnrversaL Carco Carriers, INc.,

\ SAS Petitioners,

o = v. .

ZACHARIAS Ruopiris, ,

° ' - Respondent.

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Statement of Interest of Amici Curiae

ad

This brief as amici curiae is respectfully submitted in

_ support of Petitioners by The Union of Greek Shipowners_

and the chante of Shipping of Greece.

| Petitioners sail Respondent have consented: to the filing

of this brief. The letters of consent are on file with the —

Clerk of this Conrt. .

“The “g/g. Hellenic Hero,”’ a “Greek flag vessel regis-

tered under Greek law, was operated | and controlled by

- Petitioners. ‘Hellenic Lines. Limited, a 35 year old Greek

~ Corporation all of whose stockholders are Greek citizens.

Respondent, also.a Greek citizen, was a resident and domi-

ciliary of Greece and was,employed and boarded said vessel

at Greece under a°Greek Collective Agreement which dic-

tated submission of shipboard disputes to exclusive Greek

Court jurisdiction’ ‘and -exelusive Greek law and contem-

plated payment to seamen, in the event of injury, of bene-

fits under the Greek law in accordance with Greek social

welfare programs.

"The Union of Greek Shinowmie, iinieiilill: under

Greek law in 1923 with a head office‘at Athens, is open to

membership of Greek owners of vessels of over 4,500 dead-

weight tons. It has a membership of 175, owning over

| 6,000,000 gross tons registered under the Greek flag. It is

the most representative of Greek owners. The Panhellenic |

-Seamen’s Federation, is 4.Greek corporation consisting of

the various Maritime Trade Unions, .ie. the Unions of

Masters; Radio Officers ; Engineers of Internal Combus-

tion, Engines; Sailors, Firemen; Stewards and Ship’s

Cooks. It is the most representative of Greek seamen.

Every Collective Agreement, including the one. in the pres-

ent case, is one bargained for and concluded by The Union

of Greek Shipowners and the Panhellenic Seamen’s Feder-

ation. Every Collective Agreement, including the one in the

- instant case, is approved by the Greek Minister of Mer-

-eantile Marine and has the effect of Greek ‘law, binding on |

"owners, masters, officers and crew of all Greek vessels of -

over 4,500 deadweight tons, even though the shipowner or

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the ter, officers and seamen be not members of The:

- Union of Shipowners or the Panhellenic Seamen’s Federa, .

tion. Thus, The Union of Greek Shipowners and the Pan-

“ hellenie Seamen’s Federation work together to conserve and

maintain the primacy of Greek Court jurisdiction and Greek

law aboard Greek owned Greek flag vessels. In addition,

The Union of Greek Shipowners’ interest extends to attend-

ance at International Gonfer€nces on questions of safety of

_ human life at sea afid tthe ‘rendition of opinions to the

Greek Government on such matters.

-The Chamber of Shipping of Gncéee: PGreck corporation

established some 40 years age with a principal office at

| Athens, is a judicia} person in the area of public law. Its

bers include all the owners of Greek flag ships, irre- |

hie of size, kind or tonnage, totalling 3001 owners -

and: about 10,364,687 gross tons. It is principally a gon-

-gultive organization. It advises the Greek Ministry of

Mercantile Marine dnd -private industry on shipping in-

_ cluding all questions of seamen employment ‘and labor

aboard Greek flag ships. It prepares all kinds of legal

and administrative measures affecting ships and shipping,

‘conducts arbitrations of maritime disputes, is represented

at International. Conferences on shipping, such ag safety

of humah life ‘at sea, load-lines, ship design and eqnip-

ment, bills of lading, oil pollution, nuclear cargo. and. in-

surance, freight rates, conference practices, port devel-

opment, trade and development, legislation; and publishes

a Bulletin quarterly in which shipping questions are dis-

cussed., Like The Greek Union of Shipowners, it has a

vital interest that Greek law and the jurisdiction of the’

Greek Courts, presérved in the Collective Agreements,

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should exclusively govern personal injury’ disputes and all

other disputes affecting the internal economy and disci- |

_pline of Greek owned Greek flag vessels.

ARGUMENT

c

Respondent ’s maritime injury aboard a Greek flag

vessel and the resultant dispute herein, admit of contacts -

with both the United States and Greece, and bring. into play

their competing laws. These competing contacts arise out

of the parties’ and vessel’s engagement in international

commerce.

This Honorable Court in Lauriteen v. Larsen (1953)

345 U.S. 571, 581, admonished that by long established

‘usage, statutes dealing with maritime matters, including

the Jones Act ‘‘have been construed to apply only to areas.

and transactions in which American law would be consid-

ered operative under prevelant doctrines of international

law’’: International commerce, this Honorable Court in

‘Lagritzen has told us, requires that there be mutual for-

bearance and that thus, if conflict is to be avoided in apply-

ing maritime law, the courts must ascertain and value the |

points of contact between the injury or transaction/ and

the states or governments whose competing laws are in-

volved. The Lauritzen Court said at page 582:

‘‘Maritime law, like our municipal law, has at-

tempted to avoid or resolve conflicts between competing

laws by ascertaining and valuing points of contact be-

tween the transaction and the estates or governments

whose competing laws are involved. The criteria, in

general, appear to be arrived at from weighing of the

-, significance of one or mo more cdnrecting factors between

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the shipping transaction reguiited and the national

interést served by the assertion of authority. * * * But

in dealing with international commerce we cannot be

unmindful. of the. necessity for mutual forbearance’ if

ay retaliations’ are to “be avoided; nor should we. forget

that any contact which we hold sufficient to warrant

application of our law to a foreign transactiow will

logically be as strong a warrant for a. foreign country

to apply its law to an American transaction.’’

As was said by this Court in Romero v. International .

Terminal Operating Co. (1959) 358 U.S. 354, 382-383:

: 2: ' ©We are not dealing with the sovereign power of -

the United States to apply its law to situations involv-

™, ing one or more foreign contacts. But in the absence

‘of a contrary congressional direction, we must apply

these principles of choicexpf law that are consonant .- -

with the needs of a general federal maritime Taw and

with due recognition of our self-regarding respect for

the relevant interests of foreign nations in the regula-

tion of maritime commerce as part of the legitimate

concern of the international community.* * * The con-

trolling considerations are the interacting interests of

the United States and of foreign countries, and in °

assessing them we must move with the circumspection

appropriate when this Court is adjudicating. issues

inevitably entangled in the conduct of our international

relations. is °

The Lauritzen Court set down 7 points of contact which

_ should be considered in determining whether or not.Amer-

ican law should be applied. They are in the order eye

1. The place of the ite 3 wee '|*

2. Law of the flag.

' 3. “Allegiance or domicile of the injured. -

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4, ‘Alleitents’ ot the defendant shipowner.

5. Place.of contrat.

6. Inexcessibility of the foreign forum.

7: The law of the forum. ;

The Lauritzen Court concluded ‘that three of .the above

were of special significance, namely, (1) the law of the ~

flag, (2) the allegiance or domicile of the injured and (3)

the allegiance to the defendant shipowner. -e Lauritzen

Court stated (pages 585-586), howéver, that:

portance’’ was to be attached to the law of the flag and that

Try ae weight. given to the ensign overktars most other

connecting events in determining applicable law,’’ so much

so that it ‘‘* *-* must. prevail unless some heavy counter-

weight appear’”’ (pgs. 585- 586). This «pronouncement was

merely a restatement of the settled American principle

that the law of the flag controls. matters relating to the

internal economy and discipline of a.vessel. Indeed, since

Lauritzen, this Honorable Court has re-emphasized the

paramount importance of the law of the flag. McCulloch

v. Sociedade Na ionale d. Marineros de Brazil (1963) 372,

U.S. 10 (Natio Labor tions Act does not apply. to

Inaritime operations of ship owned by foreign subsidiaries

of American. corporations, rewed ies alien: seamen. )

Thus, this Honorable Court bad made it clear that the

ultimate issue in judging the applicability of’ the Jones Act

is whether the existing factors: establishing. a connection

with the United States are sufficient to outweigh ‘‘the most

vénerable and universal rifle of the flag.’’ .

cardinal i im- .

7

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The Fifth Circuit well recognized this standard, but _

found a ‘‘heavy counterweight’’. to the flag, namely, that

the ‘‘Hellenic Hero’’ ‘‘was-for all commercial purposes

owned and operated by a United States domiciliary”’, or

- more precisely, that ‘‘Hellenic Lines Ltd.,’’ the operator

of said vessel and the employer of Respondent, Kad a base

of operation in the U.S. and its majority stockholder, al-

though an alien, was a resident of the United States.

‘Commercial presence, founded upon a base of operations

and stockholder~residence in the United States, was not

one of the points of contact which this Honorable Court set _

forth in Lauritzen. This Court voiced no concern over

‘competitive economic benefits arising out of the selection

.. of competing systems of law.. Such concept was ‘greatly.

stressed by the injured seamen in Lauritzen. As to this,

the Lauritzen Court said: — f

.8 ‘Respondent places great firess upon the assertion

eg petitzoner’s commerce an@ contacts with the ports _

the United States are frequent and regular, as the

sis for applying our statutes to incidents aboard his °

ships. But. the virtue and utility of sea-borne com-

merce lies in its frequent and important contacts. with:

more than one country. If, to serve some immediate

interest, the oer s of each. were to exploit every such -

contact to the limit of its power, it is not difficult to see

that a multiplicity ef conflicting and overlapping bur-

«dens would/blight international carriage by sea. ef

The Fifth Circuit went furthér in its theory of commer-

cial presence. It held that commercial presence, per sé,

allowed it to pierce through the Greek corporate structure

of the owning company, ‘‘Hellenic Lines Ltd.,’’ to the

residency of the alien majority stockholder so-as to reach

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convenience or sham. The authority upon whiclithe Fifth

Cireuit performed this piercing ‘exercise counteracts the

basis of the Court’s decision. The misplaced authorities

are those eases which hold that ownership of a foreign flag

7 ' yvessel by an Amerjcan citizen (corporate or individual) in

>| and of itself, is safficient to make the foreign flag illusory,

\ and this is so’ despite the foreign formalities. and.device

} including foreign residence ete. which the American places

between himself and the flag. The cases pronoiince no

more than the well’ establishe mciple of international -

law, ‘which allows a state to govern - the conduct of itétown

) citizens on. the high seas,” in foreign countries, etc. . Buch

principle was discussed by this Honorable Court i in Laurit-

zen, wherein it stated at page 587 :

.**A state is not debarred by any rule of interna-

tional law from governing the conduct of its own citi-

zens upon the high seas or even in foreign countries

/ or where the rights of other natjons or the nationals

are not infringed. (Citations omitted.) Until recent

times this factor was not a frequent occasion of con--

flict for the nationality of ship was that of its owners.

But it is common knowledge that. in recent years the

practice has grown; particularly among American ship-

owners, to avoid s ro mir’ shiping laws by. seeking

foreign registration; agerly offered by some countries.

Confronted with such operations,

sion have pressed, béyond the fo

ur courts on occa-

lities of a more

Ye or less nominal registration te enf ce against Ameri- .

can shipowners the obligations which our law. places _

: upon aneet / ; ane :

. “Iti is worthy to cits that nowhere in its opinion did the

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. the a tit the ‘‘Hellenic Hero’s’’ flag was one of

: Fifth * @tvenit mention the numerous and substantial con-

"

3

tacts with ditt of i Greek plaintiff, his Gréek dicadeaah

Hellenic Lines, Ltd., the Greek owning company and the bor res

- Greek flag” vessel, itself. It is submitted that:these contacts

were more than sufficient'to show that the Greek character

of the ‘‘Hellenic Hero’s’’ flag and of the owning company

- were more than mere formalities. ‘In any event, this Hon-

orable Court in Lauritzen, by ‘implication, announced that,

citizenship of the defendant shipowner is to be considered

‘without heed paid to concepts of residency or.economic ad-. -

vantage or disadvantage. While one of the contacts, which :

_ this Court stressed, was the “« Allegiance: or Domicile of the_ ;

Injured’’ seamen, in talking of the defendant- shipowner, it ©

merely used the term ‘‘Allegiance’’. It must be assumed

hat this Court gave thoughtful reflection to use of the

phfase ‘‘ Allegiance of the Defendant Shipowner’’ and used

it against the backg#eund of international maritime law,

_ which, it’ is submitted, doef’ not admit that allegiance

should be based onthe transitory concept of residency,

or base of operations or that it should be defined in terms

of economic ties with the United States. , It is noteworthy

that the Second Cireuit in Tjonaman v. A/S Glittre et al.,

340 F. 2d 290 (2 oA

reh. den. 382 U.S. 473 (1965) inserted the word ‘‘national’’

_ before the phrase “Allegiance of the erespecssad Ship-

_ owner”, . Re i

A.

The idea of doing aT ae in or with the United States

is essentially one of fragmented location of that part of

foreign commerce between nations: The business is largely

_ where the cargoes are. The United States because of its

prodigious wealth has, at this time of history, an advan-

igs a ta si position in international commerce; To ex-

1965) cert. den. 381 U.S. 925 (1965) © -

-32

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halt the. commercial presence of alien corporations and

ships in the United States over foreign flag and corporate, .

‘structure, it is ‘submitted, ‘i ‘is nothing more than a national- —

istic or chauyinistic exercise which stands as an affront to

Re

"international comity, the. sensibility of foreign sovereigns

and as this Honorable Court stated “would blight enterne,

tional. carriage by sea’’. . .

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ee “The international complications of this postal if

sanctioned by this Honorable Court can not-be underesti-

mated. The great merchant fleets, passenger and cargo

4 Vessels, of sovereign powers trade continuously, systema-

tically and substantially with all the major and minor ports

_ of the United ‘States. - Concomitant with this trading, they

maintain extensive offices, carry on extensive solicitations,

~ business and financial operations in the United States, in-

deed far greater than the Petitioners here. Should we say

to the Cunard Line, French Line, Italian Line, Holland-

American Line and others, ‘your commercial presence in

‘the United States; i in and of itself, ‘overrides your flag and -

you are subject/to our laws without: reference to your own

‘ldws’’? It is submitted that these questions answer. them-

selves.

The Fifth Circuit’s decision in the instant case is in

direct and utter conflict with the decision of the-Second ©

Circuit fh Tsakonites v. Transpacific Carrier Corporation,

368 F. 2d 426, 2 Cir. 1966, cert. denied 386 U. 8. 1007.

In Tsakonites, the Trial Court and the Court of Appeals,

a. Joel and ‘respected Admiralty- Court, revieweil and

carefully considered the United States residence of the.

majority stockholder and the United States base of busi- _

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Tess, sncabliage of the Greek sediail and held that these were

not sufficient to outweighs the Greek flag. Tsakonites ‘was |

* followed i in ' Nikitas Missos et al.. v. Transpacific. Carriers

Corp. and Hellenic Line3, Ltd. in the Southern District of —

New York. The memorandum opinion Y of J nudge. Frankel -

is annexed as Exhibit A. After the.decision dismissing the

suit, Christos Giakoumis, one of. the plaintiffs, -knewn as»

<. Christos S. Yovoumis, made claim and received an award —

_ by a Greek Court. Annexed as Exhibit B is a centified true

| translation of the decision fromm Greek into Pogieh.

ta: apapiinsiadiig the importance. of internal discipline

- aboard a foreign fla vessel the resulting consequence ‘in

choice of law, this Court said in Lauritzen at pages 585- —,

+586: : | RRS :

‘‘And so by comity it came to be generally under-

stood among civilized nations that. all matters of dis-

cipline and all things done on board which affected

Only the vessel or. those belonging to her, and did not ©

_. involve the peace or dignity .of the: country, or the

_ tranquility of. the port, should be left by the local

governmerit to be dealt with by the authorities of the -

nation to which the vessel belonged as the laws of that

nation or the. interests of its eommerce should re-

quire. * * #9)

6 | This was but a repetition of settled \arherican doc- :

trine.’’ .

A It. is submitted that in the circumstances of this case,

it is in the interest of Greek commerce and Greek law that _

-accidents to Greek seamen aboard: Greek flag vessels owned —

by Greek corporations be dealt with by Grebk law and ey

Greek Courts. The presence of Hellenic bor wae Ltd. and

es

its majority stockholder in the United States and the ship ’s

visits to American ports are consonant with comity and

of the United States or the ‘Heanqailty of her ports. -

™~ :

CONCLUSION,

_ Greek Shipowners, as amici: curiae, respectfully ask

=n of the law of the flag.

; Respectfully submitted,

Joon R. SHENEMAN

Zock, Perriz,.SHeneman & Rew

Attorneys for Amici Curiae -.

19 Rector Street |

New York, New York 10006

‘“Epwin K. Rew

~ @zorcz D. ByEnzs.

Of Counsel

American law and have not involved the peace or dignity -

The Greek Chamber of Shipping. and the Union of |

this Court to reverse the opinion below denying the.

13 inves

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| / i | Certificate of Service

| This is to. certify that on the 26th day of February,

‘1970 copies of the above Brief thereof have been pases

' to:

Grctge F iy “Wood of Pillans, bin: anes Wood &.

Roberts, Attorney for Petitioners, Hellenic Lines, Limited

and. Universal Cargo Carriers, Inc., whose consent to file

this brief has been obtained, at his office and post office

— address, 510 Van Antwerp Building, P.O, Box 2245, Mo-

‘bile, Alabama 36601. :

Joseph B. Stahl, Attorney for Respondent, Zacharias

Rhoditis, whose consent has “been obtained, at yris office

and post office address, Baronne Building, New Orleans,

Louisiana 70112,

*..

\, Joun R. SHENEMAN

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PRABKEL, DJ ie

| ‘Fads oe Ao tn aL eetarial reqposts Aaewttonl with

tankonites v. + 206-7. Seppe 628

(8.D.m.¥. 1965). aft'a, 368 7.24 426 (24 Caz. 1994), i

ie involved tho seme defendants. wae Aetentants fled the poneme

; _ otion for cumary judgninit, plaintiffs’ main contention was |

"ape

__ that Zenkonites tee mot yet © im precedent becmuse it ws |

ie pending on petition for a writ of certiorari. Poe metitton dew

‘since been denied (Oct. “FB. Mos. 1325, Apeil 17, 1967), and ig

“the partion have stipaiated the taste leaving 1s ; en:

_) the controlling force of Rashaniten. 5 vie oF

Accordiogiy, the action for Samary eopuant w£il be,

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Done DE 'GRECE 9,393

UNISTERE DES AFFAIRES ETRANGERES re Me pein 2S ts

Number 423 - ;

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7

ock p.m. potere me, , Al. Pilinos, —

nd for Piraqus and-in the presence of the ClerkyArteaas |

resident of the isle of Ikaria, (card of identity “4.325.0017/66)

5 wees. WHO set forth, declared and mutually acknovledged .

the following: : v

Christos Yacounis declared that upon agreenent with

the Representatives of the aforesaid Company, drawn up in Pirests,

he let on lease his services as sailor sboard ie cargo

gessel , managed by the sait Vompany, HELLENIC LRABER® with

Contracts. shat in execution of that agreesent,he vent to

> eS pices, on, this facie eee the 2etn day of the aout a

of February, in the year 1968,nineteen saxty eight . at one ae Se.

Justice of the ote wake

, salary and upon other conditions 8 provided by the Prrectss 4

— ee

_ gatarnes on beard the osid Vessel wi re he etteree “

$s Voceaber 29 1966, viiew he vas Wisaissed ia ‘|

ba. “ovine to 0 aocitent of vbich be fehl victian .

4 2, OR y ts

ge a raqpit of Bis fat frei a meer

are ‘weere be wen vith other mcabers of

a abye and, given ‘that bis

lag'esetady satary rduting the £2 gonthe snscdiately preceding

tx : 1 aoanted to érecande 6.652 of their equivalent

Ty abe A ee At 0,12.5 anc b) beara

eee

, aidhardaety w eo cousicce

wodis iy esha competed of his

78 te B aoreiee, and ig, therefore @atities to as

enonnting to he” following #ua.i.e, 3, Aoording to

the previaton of the paracraph 22 the art, 9 6f the Royal

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~sME DE GRECE 5a

__4€ DES AFFAIRES ETRANGERES Or a ; Bila ns. 5 ws

“ SuRAy Ba TRADUCTION — Egy Ps : &

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Decree of the “voyal Decree - “He: ‘Asendseat of the “Act nt 55%" 55

ge asended - b; the arte 4 pare.¢ of the Act ne 4703/1930 » in

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is aN conjunction with the cezmon.decicien | ne 58904/1957 of the *

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he istere: ‘of public Wo Bs aerchant Warine and canner ’ which

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provide that the indemnity cue “once for all in the weit pt

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partial persaxert impotence ,due.to a: lebour accident, aaa

of (he sextuple of the cum by which the yearly revenpe Pe

- tie victis was didiuisned or may be ‘ ¢dainighed OR. 4 ss ;

} froa salary of the victja, ani in the case bf ican ae Die ei a

exored-ng 30-000, Grachase thirty thousand , “the” onr fourthet

such excess is adada hee fitters S Jing PO py EB

ut $0, on thP basis of. f: shantee meniaay: salary of 6.8352 tie

trachase the indeaity due PEE to drachane 145.251. rarther

5 the game de entitled to bebe; geeliecen éalaries/for 75 aye a4

\gpat of any clinic, at the rate of 244-0 per th and. further 7

saleries of 45 daye ‘dn clinic ac 31.4.0 per 2o..th, 4.¢6, he ai

entitled to receive in all fo e s:id reason & 1.10.0

Of drachase 8.976, st the et rate of the British pound,

“Les he‘ is entitled to receive in all, Grachuze 154,227 énc bun-

st

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ne al

_ G@rea@ end fufty. four thousend two hundred and twonty seven 5

on account of ‘which suc he recognizes end acknovhesgve that :

he hee already received’ froa the *liellenic ines. outa" 1” &

mutiatir,” ‘against receipts drezhnee <9.060 ‘twenty nine thousand

.end sixty ao that it-resaiss e reaainder to be received froa

the. mancging the sfores id chip Coapany * ‘4HE MELLEare .

’ LINES, aud ® BLLAXIX _ of Drs. 125.167, which’ the said Coupany

Jap oD 0 my s0 to his ~ ;

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FE > (4) . ee ee ee haat ye

fae attorney-aeles of the eid Coapanys: HARICLIA ANAREO. | ig

0. declares that a2 though che denies ang rejects the -. ‘ 2

: ate Ghrisioe tacowify, ait « alec his cleiss in general ;

‘any support by lay and the anttée,. 00 wueb-

atten. hes’ uot suffered the aceicent. iavoned inthe |

» thst bir soiiinn atenh siahsslepinh te the us Soy

pid nar thet he becase totally iapotent: te wort ;

.

:

eserk le Haid Chtatos Tecouats, in our’ Pr. cance, the eus "

. ia -oclared ‘that he cossidern ‘ackrov= ~ eas

es hincelf telly ind. ani‘ied ané gatasticd | i

. :

7a S

. iS ) ee

a . Of any his claiz 6..6 pretent.on Sedinet the ranager of the ‘ga

s werucl, *the eitente Lines ,bta" ite repr.eentatives, ovaera, -

j.|, . operatoras exew , incurers and Agente of ‘the hip . Hellenic.

fa 3 Leeoer® deriving from his bei ing been. wouncee on sot sl of the -

eaid ship snc general :; fro: a hde. ‘AShe: tervice on Yoare of tae

ease ,either on the ba.is of the vo¢ifrec pax 5e $3, ve ES fe’

, BP fore, arsagy! ot Pabcnaseen al ts

-Private‘taw ‘ope ané sore eepecaatay trex its thats an

\ eigtee ana farievictiogy ia th tals oF in enarther country, euch as

any write of procees .nd righte ve}cus persons, copecially wy

reason of aorul prejudice, acknowledging enc. Fecognizing that

ali aforeedic pervone have n0 other reeponcioitlty or obliention

by reason of bis secicenty, dee to bis own feuis and Feeponesbitity

eee

>: and not te any ae. wtudoal- defect or deficsency of the ship

bid har eppurterancee, nor to aay dole, egiect or act of qntzeton of

ze the officers and of the crev or the nen charged to charse@ or

sascharge the vessel, her owners , aanagers, insurers and agents :

“Moen fay pereon or percons appointed by the ovners|

ear se

Pe — ort “s

. “oe

: s

(6) me,.92993_

nor, to. any “traxsgrescions of act anc fules by the the persons

% : appointed for the surety of the crev, but . to the contrary,

“4 to hie own. jin cince acd villing transgression of the Lave and

on8,. and renounces expressly and without any reservation

pat to attack i Sl reasonforasl or |

. / my ~™

SS “ame Baissea sol in-ancreopouton, in her, capacity, in

at snd acts , declared, that she accepts in the

- . contrasting pestiee declared that they

: ot ‘soste of taddd presents.

iason hevaiet <a aloud ed aistinotly in tke. heering. of b11

Lie ee

pe tties: herejn anc confirmed are signed: in ‘due ford of law by -—

al-end ae » the Justice of the Ponce, after payncnt of the stamp ©

ores? ra As Ps

_ fe — whieh. the receipt ia triplicate a lasy4 ‘of the:

2 Clerks : “the poreecos of the Pe-ce:

~Manthou — . Al.Pilinis

AE DE GRECE

AFFAIRES _ETRANGERES

| acho: | 3 8 Lae a: no 9.395

Fa e

Ge .

e

A Tre E cop % \ ‘

is Suiies¢ ten 285 1968.’ The Clerks TR. Billias, E48,

: _This 4. to hertit, the genuineness of the eienatare

- of the Gerk who ivsued the- copy , Theodore Bilias, Judicial

Sui-Clerk of the firet elec. ic sar Service - and also of the . e

Clerk of first clase who vicaea its ai .

4 In Firaese,! April 2, 1968 The Bead of the offices ae

" Of the Justice of the Peace, 1: 2:6, for Piraeus, Jaye: 4

: ; ee Das In Piracae, april 2, 1968. eh sh a5 A ket,

* The ‘Head of the Justice of the Seine Oftises or: Masewae ae

Signe : eB.) Tegible ciguetuic (qe Peatiastrojonis, sucot ee

rs « ths firet Anatance. ap bene eee se a .

ai oe

® ‘ fr

of, the dedeis of the tirct Auotauce of Pireeus’, Panay.

éiaitropoules, ' Athens, April 2, 1968 Te Presicent of. ap

Court of ice ‘iret dustaac.- of Piraeus: (4.3.) E. Dialjnas =

TAis is to certify the. oemeatee of the si:nature of:

ari z, Dialena, aie ys of the Court ‘of. the firet instance of —

Pireeus. = !n itheno , Apral 2, 1968, By eutnority-or the |

Miaister of eitinws The C:..ef of Bureaus: (L.£.) (ga) 1:Kryos, a

* SSEN for its correct otamping anc tinaly del ive ry.

=

x

‘ 40 Sireeus ,evon cate. The Chief of Bureaus (2,8, Allegible

Slgcetane. ; ‘

A ‘TRUE ‘TRANSLATION

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