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Frank Sioli, Kristina Alexander & Joanna Pino
• Seaman Claims seen on Yachts
Jones Act Negligence
Unseaworthiness
Maintenance & Cure
Burden of Proof at Summary Judgement
• Limitation of Liability
• Passenger/Invitee Claims vs. Borrowed Servant
• Maritime Coverage Issues
• Marine Salvage
TOPICS WE’LL COVER
• We will review some legal theories and cases addressing a variety of maritime mishaps…
• Then we will see if you can guess how the court ultimately ruled,
• And next review the court’s (sometimes bizarre…) rationale.
WE WILL LEARN FROM OTHERS’ MISTAKES—GAMESHOW VERSION
MAINTENANCE CURE
• Includes the room and board of the injured seaman while recovering from the injury at home.
• Expenses include seaman’s rent or mortgage, utilities, property taxes, homeowner’s insurance, and food.
• Does NOT include telephone, cable, internet or car payments
JUST THE NECESSARY EXPENSES OF RUNNING ONE’S HOUSEHOLD.
• Includes the injured seaman’s reasonable and necessary medical expenses along with the cost of transportation for getting his/her reasonable and necessary medical treatment up to maximum medical cure (MMC)/maximum medical improvement (MMI).
• Similar to workers’ compensation for an injured land-based employee
Seamen who are injured while at the call of the vessel are entitled to maintenance and cure from their employers.
MAINTENANCE & CURE
Injured Seaman receives Maintenance and Cure until he/she reaches a point of Maximum Medical Improvement (MMI).
PUNITIVE DAMAGES FOR FAILURE TO PROVIDE MAINTENANCE & CURE
• In a 5-4 decision, the U.S. Supreme Court affirmed an Eleventh Circuit holding that, as a matter of General Maritime Law, punitive damages are available for the willful and wanton withholding of maintenance and cure.
The decision in Atlantic Sounding v. Townsend, 129 S. Ct. 2561 (2009), operates onthree premises:1. Punitive damages have long been available at common law as a remedy for
wanton, willful, or outrageous conduct.2. The general rule that punitive damages were available at common law extends to
claims arising under federal maritime law;3. Nothing in the Jones Act or general maritime law undermines the applicability of
the general punitive damages rule in the maintenance and cure context.
CLAIM
• Yacht stewardess sued employer for:
Maintenance & Cure: Alleging Employer failed to provide prompt
& adequate medical care.
VAN MILL V. BAY DATA, INC. - 2002 EMPLOYER’S DUTY OF CARE TO
CREWMEMBERS
• Yacht stewardess injured both arms lifting heavy equipment
• Captain brought stewardess to hospital for treatment.• Doctor at hospital put her arm in a sling, and told her to
perform only light duty work on return trip of yacht• Stewardess refused to keep her arm in the sling, declined
the captain's offer to have her flown home, and insisted on continuing to work.
• Further, upon returning to Fort Lauderdale, she did not immediately seek medical attention and exacerbated the injury and allegedly also injured her other arm by agreeing to do maintenance work on the boat, including sanding and varnishing, while it was in dry dock.
FACTS
• Stewardess was ultimately diagnosed with lateral epicondylitis, commonly called “tennis elbow” and underwent surgery on both arms over a two-year period.
• Employer paid for the surgeries and also paid for maintenance, or living expenses, during that time.
• Ultimately, the Stewardess was limited in what she can do with her arms, cannot resume employment as a stewardess, and was unable to find comparable employment/salary.
• She sued for Failure to Provide Prompt & Adequate Medical Care (Cure) based on the aggravations and delay in medical care she sustained because she continued working.
FACTS
Does the stewardess’ refusal to cooperate with the Doctor’s orders negate her maintenance & cure claim against her employer?
OR
Is the employer still on the hook for maintenance and cure even though the crewmember didn’t ask for and specifically refused medical care, as well as voluntarily disobeyed Doctor’s orders after her injury?
HOW DO YOU THINK THE COURT RULED ON FAILURE TO PROVIDE
PROPER CURE?
Maintenance & Cure—Seaman Wins
Holding:• The yacht owner was NOT relieved of its responsibility to the
Stewardess simply because of her refusal of assistance or her failure to follow directions.
Reasoning:• Despite all of the evidence suggesting that the
Stewardess declined the captain's offers of assistance, ignored doctor's orders, and contributed to her injury, the law places a greater obligation on the captain to provide for crew members' welfare than it does on the crew members themselves.
HOLDING
• Regarding Maintenance and Cure, a captain/employer has a heightened duty of care to the wellbeing of its crew.
• Maritime employers are required under the doctrine of maintenance & cure to insure the wellbeing of the crew whether or not the crewmember requests such aid!!!!
• Relationship between Employer and seaman has been called Ex Loco Parentis—Treat injured seaman like your own kids…or beloved Pets! ;)
WHY IS THIS CASE IMPORTANT?
• The Jones Act is a Federal law which allows injured sailors to make claims and collect from their employers for the injuries as a result of negligence of the ship owner, the captain, or fellow members of the crew.
• Under the Jones Act, a maritime employer must provide the seaman with a reasonably safe place to work, and must use ordinary care to under the circumstances to maintain and keep the vessel on which the seaman works in a reasonably safe condition.
• Very low burden of Causation for seaman—the plaintiff need only prove that the employer’s negligence played any part -- however slight -- in the plaintiff's injuries.
SEAMAN PERSONAL INJURY CLAIMS: 1) THE JONES ACT
• Under the general maritime law, injured seamen can recover damages from the owner of the vessel on which they were injured if the vessel is deemed unseaworthy.
• Under maritime law, a seaworthy vessel is a ship whose hull, equipment and crew are reasonably adequate or fit in design, maintenance and character to perform their intended functions in the operation of the ship.
• An injured seaman does not have to prove that the entire vessel was unseaworthy or that it was in danger of sinking. All that the injured seaman needs to prove is that some condition or aspect of the vessel, equipment or crew was not reasonably fit for its intended purpose, and that he/she was injured as a result.
SEAMAN PERSONAL INJURY CLAIMS : 2) UNSEAWORTHINESS
Yacht steward sued employer for: Negligence Unseaworthiness
This Case involves an appeal from a Jones Act and Unseaworthiness Summary Judgement ruling
in favor of the Employer and Shipowner.
LANE V. TRIPP
JONES ACT & UNSEAWORTHINESS
• Crewmember was employed on 90-foot yacht.
• During the course of a voyage to Maine, the vessel stopped in Atlantic City, New Jersey.
• The crew started to clean the vessel. After cleaning the Eisen glass, a crewmember attempted to dismount the console, slipped on a wet footrest, and severely injured his knee.
FACTS
• Claim for Jones Act negligence & Unseaworthiness based on wet footrest.
• Trial Court granted Summary Judgement for Defendant on Negligence and Unseaworthiness Claims, Plaintiff appealed…
• Is a wet footrest enough to sustain a Jones Act claim against the Employer?
• Is a wet foot rest enough to sustain an Unseaworthiness claim against the vessel owner?
HOW DO YOU THINK THE COURT RULED ON APPEAL?
Jones Act Negligence: REVERSED• The trial court erred in granting summary judgment on the plaintiff's Jones Act
negligence claim because the plaintiff adduced sufficient evidence to satisfy his burden of proof.
• In a Jones Act negligence case, the movant for summary judgment bears a more onerous burden than in other cases.
• There must be a complete absence of probative facts to support a claim of negligence before the court can grant summary judgment.
Unseaworthiness: REVERSED• Summary judgment on an unseaworthiness claim can be granted only where
reasonable minds could not differ on the question of whether the unseaworthy condition of the vessel caused the plaintiff's injury.
• The issue of whether the footrest was unseaworthy due to the lack of non-skid coating is for a jury to decide.
HOLDING
The Lane Court highlighted 3 important things to know:
1. Summary Judgments can be Fool’s Gold, as the prevailing law is still that the plaintiff has a featherweightburden to overcome a motion for summary judgment in a Jones Act negligence case.
2. An employer/shipowner may be liable for a temporary negligent/unseaworthy condition.
3. Appellate courts almost always look for ways to reverse summary judgments, because summary judgments take away the Plaintiff’s right to a trial.
WHY IS THIS CASE IMPORTANT?
LIMITATION OF LIABILITY ACT (LOLA)
46 U.S.C. §§181 – 196
• In the United States Maritime Law, the Limitation of Liability Act allows a vessel owner to limit its liability after a maritime incident or casualty to the post-casualty value of the vessel and the pending freight, unless the cause of loss was within the owner’s “privity or knowledge.” 46 U.S.C. App. §183(a).
• In other words, privity or knowledge will be found to exist where the acts of negligence or unseaworthiness that caused the casualty were previously known or should have been known by the vessel owner.
ONLY APPLICABLE TO CASUALTIES THAT TOOK PLACE ON THE NAVIGABLE WATERS OF THE UNITED STATES
• 6 Month Rule• A limitation of Liability proceeding must be commenced within 6 months after the vessel owner receives
written notice of a claim that may exceed the post-casualty value of the vessel, plus pending freight. 46 U.S.C. App. §185; Fed.R.Civ.Supp. Rule F(1).
A Powerful Tool For Vessel Owners Against Personal Injury Claimants
CLAIM• Decedent Plaintiff’s estate filed negligence claims
against the District after fatal boat accident between a speedboat and a ferry owned by the Transportation District.
• The District, in turn, filed a complaint for exoneration from liability under the Limitation of Liability Act. (LOLA)
HOLZHAUER V. GOLDEN GATE BRIDGE HIGHWAY & TRANSP. DIST. - 2015
• Plaintiff, Harry Holzhauer, and a companion were traveling on a speedboat on the San Francisco Bay.
• The speedboat collided with a ferry being operated by the defendant, Golden Gate Bridge Highway & Transportation District, killing the plaintiff and injuring his passenger.
• Prior to the collision, the powerboat operator made a sharp U-turn, was viewing the San Francisco skyline and not paying attention to the boat’s movements
• At the time of the accident, the captain of the ferry was using his cell phone, and the Ferry boat owner had general knowledge of this practice.
• Defendant moved for Summary Judgment on Plaintiff’s negligence claim
FACTS
At Summary Judgment:
Defendant argued:• Speedboat was in violation of Inland Navigational Rules [failure to
post an adequate lookout] at the time of the collision and is therefore presumptively at fault.
Plaintiff argued:• Regardless of whether the speedboat was in violation of the rules at
the time of the collision, the Ferry itself was in violation of the Rules and thus the Vessel is not entitled to limitation.o Arguing that Ferry Captain’s cellphone use constitutes lack of
adequate look out, and that the owners had prior knowledge of the cell phone use.
FACTS
Does the owner’s general knowledge of the Ferry Captain’s cellphone use constitute privity and knowledge of a factor that potentially caused the incident, thereby precluding Limitation?
HOW DO YOU THINK THE COURT RULED?
• Court determined a factfinder could conclude that, even if the powerboat was engaged in numerous violations of the Rules at the time of collision, the Ferry was also in violation of the Rules and may bear some responsibility for the accident.
THEREFORE, THE DEFENDANT’S MOTION FOR SUMMARY JUDGEMENT WAS
DENIED• The court reasoned that the District failed to meet its burden of
demonstrating a lack of privity or knowledge of the captain's conduct (using his cell phone while operating the vessel).
• The District had no policy regarding use of personal cell phones by its captains, knew its captains carried personal cell phones while operating its ferries and permitted their use, and the captain was using his personal cell phone to speak with shoreside personnel at the time of the accident.
HOLDING
Limitation is a very powerful tool that may benefit owners have no
involvement in the loss.
HOWEVER, IF AN OWNER IS SHOWN TO HAVE ALLOWED CONDUCT TO
OCCUR (SUCH AS CELL PHONE USE, ETC.) WHICH ULTIMATELY CAUSED THE
LOSS, LIMITATION MAY NOT BE AVAILABLE EVEN IF THE OWNER WAS NOT
PRESENT ON THE VESSEL.
WHY IS THIS CASE IMPORTANT?
The law of Insurance policy contract interpretation generally holds that:
1. Any ambiguities in the policy must be construed against the insurance company,
as the insurance company drafted the policy, and
2. Insurance contracts are contracts of adhesion, where the insurance company
has unfair bargaining over the insured. Thus, where a sophisticated insured
sells insurance to a customer, the policy will be construed against the insurance
company.
INSURANCE CONTRACT INTERPRETATION
CLAIM
• The insured, yacht owners, filed an action against their insurance company for breaching its duty to defend owners in a third-party liability action after a collision in the Oregon side of the Columbia river based on a navigational limit clause.
SULLIVAN V. CERTAIN UNDERWRITERS AT LLOYDS - 2016
• The navigational limits clause of the policy limited coverage to "the use and navigation of Washington and British Columbia including the inland lakes and rivers." The yacht was in the Columbia River, which boarders the States of Washington and Oregon.
• At the time of the accident, the insured yacht was located on the Oregon side of the Columbia River near the City of St. Helens, Oregon. Defendant asserts that because the yacht was not in Washington at the time of the accident, coverage is excluded based on the navigational limits clause.
• The court asked if the navigational limits clause confines coverage of the vessel to the "rivers" of Washington or the "inland river" of Washington. In other words, does "inland" modify both "lakes" and "rivers" so that the clause means "inland lakes" and "inland rivers" as opposed to the clause meaning "inland lakes" and "rivers".
FACTS
Did the court rule that the insurance carrier properly denied coverage based on their the navigational limits clause, because the loss clearly occurred in Oregon, outside of the navigational limits of the policy…
OR
Is there an ambiguity of the navigational clause to allow the insured boat owner the benefit of coverage?
HOW DO YOU THINK THE COURT RULED?
The Court held that the Plaintiff was entitled to coverage
• The Court found that the phrase "inland lakes and rivers" is ambiguous as to whether it includes "inland lakes" and all "rivers" or only "inland lakes" and "inland rivers." Thus, construing the ambiguity against the insurer, the court found that both the Washington and Oregon sides of the Columbia river were within the navigational limits of the policy.
HOLDING
• Serves to highlight that courts will construe any vagueness or ambiguities in the policy in favor of the insured.
• A related doctrine followed by a number of states, states that insurance policies are contracts of adhesion, and should be construed against the drafter of the document…usually the insurance company.
WHY IS THIS CASE IMPORTANT?
CLAIM:
• INSURED BROUGHT ACTION AGAINST HOMEOWNER’S INSURER TO
COLLECT POLICY BENEFITS FOR SINKHOLE DAMAGE
JOHNSON V. OMEGA INS. CO. - 2016
• The Insured filed a claim for benefits to her homeowner insurance provider, Omega, alleging property damage from sinkhole activity.
• Initially, Omega denied coverage after its experts inspected the Insured’s property and determined that there was no sinkhole activity.
• However, the Insured hired independent experts, who opined that the Omega’s investigation was insufficient and determined that the property damage was due to sinkhole activity.
• The Insured filed a legal action against Omega for breach of contract, requesting the benefits to which she was entitled under her policy, along with the accompanying attorney's fees and costs.
FACTS
• As a result, Omega filed an Answer and Affirmative Defenses, in which Omega finally admitted that the Insured was entitled to benefits to cover the damages and paid for some claims.
• The Insured subsequently filed a motion for confession of judgment and a motion for attorney's fees, costs, and interest, contending that Omega's admissions amounted to a confession of judgment.
• The trial court granted the Insured’s motion for confession of judgment and attorney's fees, and thereafter entered an order for Omega to pay attorney's fees, taxable costs, and prejudgment interest to continue to accrue at the statutory interest rate until paid in full.
• On appeal, the Fifth District Court reversed the trial court's order granting the attorney's fees and cost award, opining that Florida law requires some type of bad faith conduct on the part of the insurance company before fees can be awarded.
FACTS
Do you agree with the Trial Court’s Ruling?• That Omega’s admissions and payment amounted to a
Confession of Judgement?
• and the Insured is entitled to attorneys fees and costs based on the admissions and the payments?
OR
Do You Agree With The District Court’s Ruling?• That Florida law requires some type of bad faith conduct on
the part of the insurance company before fees can be awarded.
HOW DO YOU THINK THE COURT RULED?
Ruling below is QUASHEDFL Supreme Court ruled:
1. the payment of a claim is the functional equivalent of a confession of judgment or a verdict in favor of the insured.
2. bad faith or degree of “wrongfulness” of the insurance company is not relevant to a recovery of attorney's fees under the attorney’s fees statute.
• Because the Insured submitted a claim, Omega denied that claim, the Insured filed an action seeking recovery, and Omega subsequently conceded that it had incorrectly denied the benefits based on an inaccurate report, the Court concluded the Insured was entitled to attorney’s fees and costs.
HOLDING
Recovery for attorney's fees under Florida law only requires an incorrect denial of benefits by the insurance company, not a bad faith denial, to trigger an attorney’s fees award.
• Once an insurer has incorrectly denied benefits and the policyholder files an action in court in dispute of that denial, the insurer cannot then abandon its position without repercussion.
If a claim is determined to be incorrectly denied, in Florida, the insured may pursue further damages if the denial of the claim amounted to Bad Faith.
WHY IS THIS CASE IMPORTANT?
Three basic elements are necessary to a valid salvage claim:
1. A marine peril.
2. Service voluntarily rendered when not required as an existing duty or from a special contract.
3. Success in whole or in part, or that the service rendered contributed to such success.”
Award value includes consideration of the danger, the value of the vessel, and the labor, skill and energy used in saving the property.
SALVAGE
CLAIM
• Professional marine salvor who undertook rescue mission for yacht in peril filed in rem action seeking salvage award for services provided to the vessel.
SALVAGE: GIRARD V. M/V “BLACKSHEEP” - 2016
• In December 2013, Arnaud Girard, a marine salvor, undertook a rescue mission for a 125–foot yacht known as the M/Y Blacksheep.
• The Blacksheep was located a few hundred feet offshore near the Galleon Marina in Key West, Florida.
• While testing the port engines' controls, the Blacksheep’s port propeller shaft had dislocated from the gear box coupling and the yacht started taking on water.
• The salvors responded within four minutes of the Blacksheep’s distress calls. At this point, there was about two feet of water in the bilge. Salvor Girard first deployed his high-capacity pump to dewater the bilge.
FACTS
• Then, Salvor Girard, along with a co-salvor, dove under the Blacksheep. They repositioned the propeller shaft, bringing it closer to its proper location.
• The salvors also installed a temporary patch to limit the amount of water coming into the boat. The Coast Guard assisted by placing a patch on the inside of the Blacksheep.
• Eventually, the Blacksheep was towed to the dock by Towboat U.S.
• Initially, the United States District Court for the Southern District of Florida denied a salvage award. Salvor Girard appealed.
FACTS
• The District Court reasoned the 1st element of a salvage award requires that a vessel:
1. be in marine peril; and2. could not have been rescued without the salvor’s assistance
• The District Court found that the Blacksheep was in “marine peril.” But, as to the second showing, the court found that “Plaintiff’s efforts were not necessary to rescue the Vessel,” and denied a salvage award.
• On appeal to the 11th Circuit, Girard argued that this second showing—that the ship “could not have been rescued without the salvor's assistance”—is not a proper element of a salvage award claim. Rather, Girard argued, a plaintiff satisfies the first element of a marine salvage claim by establishing only “marine peril.”
HOW DO YOU THINK THE COURT RULED ON APPEAL?
The 11th Circuit reversed in favor of Salvor
• To satisfy the first element of a salvage award claim, the salvor must show “marine peril,” but need not make the additional showing that the ship “could not have been rescued without the salvor's assistance.”
• Because the District Court found that the Blacksheep was in “marine peril,” Mr. Girard has established the first element of his salvage award claim.
• The 11th Circuit reasoned the added “necessity” requirement is inconsistent with both Supreme Court and binding circuit precedent, and also undercuts the policy interests that the salvage award is intended to further. The law of salvage is rooted in a public policy to encourage mariners
to come to the aid of a ship in distress.
HOLDING
• In addition to the duties a vessel owner has to its crew and to other vessels, the owner of a vessel has a duty to utilize reasonable care and prudence to provide for the safety of invitees on board the vessel, such as passengers and independent contractors.
• This includes the duty to warn of and eliminate dangers it knew or should have known in the exercise of ordinary care.
• With regard to independent contractors, be careful of the borrowed servant doctrine, which may deem an independent contractor, or an employee rented or leased from another company, to be a seaman. That injured contractor would then be able to claim maintenance and cure, unseaworthiness, Jones Act negligence, etc.
• Control is the key to look for as to whether a borrowed/rented/leased employee has become a seaman for the vessel.
VESSEL OWNER DUTIES TO THIRD PARTIES: PASSENGERS &
CONTRACTORS
WHAT HAVE WE LEARNED…?
LAW SCHOOL HYPO TIME!
• The 100 Foot M/Y Dolphinz Delite (value 1.5m USD) set sail from Miami’s Diner Key Marina on a three-hour cruise to Bimini with a full crew and a small complement of guests of the vessels owner, and owner of the Miami Dolphins, Dolfan Denny, who was not present on board.
• The crew included Ami Dee, the yacht’s fitness instructor/staff captain; it’s Captain Jim Stubing; First Officer Johan Walquer; and seaman Jeeves Patall.
• Passengers included Kelli, Kimmie, Georges, Shelly, Donya, Aimeee & Franc, who religiously attended Amy Dee’s stepper-cize sessions on previous voyages.
WHAT HAVE WE LEARNED…?
HYPO TIME! SLIDE #2
• In addition to the crew, the ship sailed with a marine electrician contractor, Allen Rented, who was leased from a local marine electric shop to work on the ship’s electrical system during the voyage. Allen brought all of his equipment with him and worked independent of the crew.
• As was customary, First Officer Walquer, a licensed master like Captain Stubing, brought the vessel out of the marina, while Captain Stubing was on the bow of the vessel serving as lookout. However, just as the Dolphinz Delite cleared the marina, it encountered a swift-moving vessel that had been obscured by a mangrove, the 150 foot M/Y Mischievous Mila (value $5m USD), owned by Donald Murphy captained by Jack Black.
WHAT HAVE WE LEARNED…?
HYPO TIME! SLIDE #3
• Aboard the Mischievous Mila, Captain Black attempted to take evasive action, but his steering suddenly failed, so he was left on a collision course. He was, however, able to slow the vessel considerably.
• Aboard the Dolphinz Delite, Captain Stubing shouted and began to run toward the bridge when he saw the Mischevous Mila approaching.
• However, Amy Dee’s step class with her squad had already begun. Step class included running all around the vessel to see who could log the most steps on their “BitFit” devices. While Amy was checking her BitFit, she ran into Captain Stubing, who wasn’t looking where he was going as he was so focused on getting to the bridge swiftly.
WHAT HAVE WE LEARNED…?
HYPO TIME! SLIDE #4
• On the bridge of the Dolphinz Delite, having believed they cleared the marina safely, First Officer Walquer and Seaman Jeeves turned to their TV on the bridge to watch the exciting outcome of the Arsenal-ManU match, which had gone to penalty kicks.
• However, when they heard Captain Stubing warning, they quickly recovered and fortunately were able to both slow and turn the vessel. Nonetheless, the vessels did collide, causing what appeared to be minimal damage to both vessels.
• The entire crew and passengers of both vessels sustained minor soft tissue injuries as a result of the collision, with Amy Dee and Captain Stubing probably getting the worst of it because they collided as well! Everyone sought medical treatment after the incident and ultimately filed soft tissue claims.
WHAT HAVE WE LEARNED…?
HYPO TIME! SLIDE #5• Although it was just a minor collision, it is later found that the Mila sustained hidden
hull damage in the amount of $2.5m. She drifts into a nearby sandbar, later regains engine power and probably would have floated off the sandbar at high tide. However, Captain Pecan accepts aid from AJ’s Towing, who sends a fleet of vessels led by Captains Paul Marques and Kelvin Pecan to pull her off the sandbar. Thereafter, AJ’s Towing demands a $1m salvage award.
• All Dolphinz Delite’s insurance limits are $5m. Her policy contained a navigational warranty that the vessel shall have a licensed master at the helm at all times during ingress and egress of ports and marinas.
• The owner of the Mila, as well as all guests & crewmembers of both vessels, filed written claims against Dolfan Denny and the Dolphinz Delite, in rem Dolfan Denny within a week the incident, but no suits have been filed yet.
WHAT CAUSES OF ACTION/DEFENSES DOES EACH PARTY HAVE?
• Ami Dee???
• Her Squad???
• Allen Rented?
• First Officer Walquer and Seaman Patall?
• Captain Stubing?
• Captain Black?
WHAT CAUSES OF ACTION/DEFENSES DOES EACH PARTY HAVE?
• The Vessel Mischievous Mila and its owner Donald T. Murphy?
• The Vessel Dolphinz Delite and owner Dolfan Denny?
• The Dolphinz Delite’s insurer based on the navigational limits clause?
• What is the value of AJ’s salvage claim?
THANK YOU FOR LISTENING!
IF YOU HAVE ANY QUESTIONS…
THANK YOU FOR LISTENING!
IF YOU HAVE ANY QUESTIONS…
Thanks for your participation!
You can find us at:
www.superyacht.law
