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6. Proposal of amicable settlement.

Further to my letter of the 25th inst. I beg to enclose herewith a copy of the Surveyor Report dated the 28th of March, 1992 in connection with the damage caused by your vessel to my ship in collision near Buoy R70 in the Houston Shipping Channel on March 24, 1992. From the above-mentioned Report you will see that the Surveyor, Mr. R. Sasoon of this city, on a thorough survey and careful consideration of all circumstances, estimates the amount at US$ 25000.00.

I hope that you will consider our claim and amount of damage estimated by the above mentioned Surveyor as quite reasonable and justified, and I offer you to settle this matter amicably by paying the respective sum of US$25000.00 to our Agents here, Messrs. Rice Unruh.

Your prompt reply will oblige.

7. Sea protest about grounding.

S T A T E M E N T OF SEA PROTEST

I,......., Master of m. v. Utopia under the flag of the Russian Federation, Gross tonnage 8092, registered at the port of St. Peterburg, International Call Sign UUSW, on...... 1992 sailed from St. Peterburg to New York with 4072 metric tons of general cargo, the vessel being tight, staunch and strong, well manned, victualled and sound, and in every respect fit to perform the said intended voyage.

On...... 199.. at 14.00GMT, approaching the port Kalundborg, in position 55N 37.0 010E 56. 5 due to the engine failure the ship began drifting to shore carried by southwest wind of force 15-20 m/sec. Inspire of all the efforts to restart the engine and stop the drift by letting go first the port and then the starboard anchors, at 14. 15 the vessel was grounded on the shoal lying half a mile North-East from the Palce of the engine failure. All the efforts undertaken to refloat the vessel without outside assistance failed and vessel had to apply for salvors services. Two salvage tugs of the port of Kulundborg were used for refloating, and at 13.00.... 1992 the ship was refloated. A divers' inspection was carried out after refloating the vessel. As no visible damage to the ship's hull was found, the vessel continued the voyage and at 6.00 local time on.... 1992 the ship was berthed at pier 7 Brooklyn Marine Terminal of the port of New York.

The crew of the vessel have applied all means to safeguard the ship and her cargo, but nevertheless, fearing damage to the cargo and the ship, and losses in connection with reflating, I declare this Sea Protest, reserving the right to extend it at a time and place convenient.

  1. Damaged cargo, request to replace

This is to inform you that today, on.... 19.. during loading of cargo of white mineral oil under B/L... into Hold N... damaged was caused to... barrels of white mineral oil due to negligent work of the crane operator who struck the pallet with the barrels against the coaching of the hatch square while lowering the draft into the hold.

The barrels are badly dented and leaking.

I kindly ask you to replace the damaged barrels before completion of loading.