4. Rejecting a claim about contract

Gothenburg, 18th October, 20 . . .

Messrs. Larson, Bersen & Oldingen, Stevedoring C.,

c/o Messrs. Sandstrom & Hans son, Ship Agents, Kustgatan, 27.

Gothenburg, Sweden.

Dear Sirs,

With reference to your claim for damage to your vessel caused by us as a result of contact with you vessel while mooring astern of your vessel to Berth 18 of Camden Terminal, Port of Philadelphia at 02. 30 a.m. 14th inst. I wish to state the following:

I regret about the contact, but the stern of your vessel and sea side were not properly lit, as required by the Regulations, which together with the fog, made it extremely difficult for us to determine the distance to your stern with sufficient accuracy when we were approaching the berth. I called the attention of the pilot, Mr. Carpenter to the fact, and had this fact duly recorded in the ship's Log Book. I am sure he will confirm the fact.

As to your allegation about our approaching the berth at an excessive speed, I assure you that our speed at the time of the contact was not more than half a knot. This can be easily verified by questioning our pilot.

As my opinion your own lack of due care, and not my allegedly excessive speed was the cause of the damage I reject your claim as groundless.

Yours faithfully,

V. I, Stepanov

Master of m/v "Chigirin"

5. Claim for compensation rejected

Stockholm, 17th November, 20 . . .

Messrs. Swenson & Co., Ship Agents,

Bangatan 10,

Stockholm, Sweden.

Dear Sirs,

Referring to your claim for compensation of personal injury to your stevedore P. Lemon, sustained by him while working on board my vessel on......,20… wish to advise you that in my opinion the accident occurred solely through your workmen personal negligence and his own failure to observe safety rules.

Immediately after the accident 2 other workers (P. W. Bota and P. Leclerk) working together with P. Limon in lower Hold 3 were questioned by my Cargo Officer. They did not deny the fact that the man was not wearing his helmet at the time of the accident. The injured man helmet was found on a stack of barrels 2 meters away. According to good marine practice they should have properly slung the wooden dunnage, or still better, they should have removed it by a separate draft. And by all means, the injured man should have been wearing protective helmet all the time during his work on board the ship.

In view of the above I consider your claim groundless.

Yours faithfully,

S.N. Soloviev

Master of the m/v "Krasheninnikov"

6. Claim for wake damage rejected

Bordeaux, 27th May, 20 . . .

With reference to your claim for damage to vessel allegedly caused by us by proceeding past your vessel at an excessive speed at about 06. 30 a.m. inst.

I wish to comment as under:

1. Approaching your vessel moored at Berth 13 Camden Terminal I reduced speed to the minimum safe maneuvering speed and this fact was duly recorded in the ship's logbook.

2. The records in the logbook also show that your vessel had her headline and backspring forward slack.

I am sure that both facts will be confirmed by our Pilot.

As in my opinion your own lack of due care and not my all legedly excessive speed was the cause of the damage I reject your claim as groundless.

K. A. Pavlov

Master of the m/v "Argun"