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August 1996
Vol. 7, No. 2
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of Contents
Contents
KEEPING THE CLIENTS OUT OF JAIL
by John
G. Ingram*
Since the EXXON VALDEZ incident, and the enactment of the Oil Pollution Act of 1990 (OPA 90), there have been a growing number of criminal prosecutions arising out of the discharge of oil into U.S. waters. As a result, maritime attorneys representing shipowners in such cases need to be aware of the potential conflicts of interest that may arise between vessel owners, their P&I Clubs and the crew. For example, during accident investigations, a decision on whether to invoke a Fifth Amendment privilege against self-incrimination may become of paramount importance to those being questioned, since they could be potential targets of a criminal prosecution.
Before OPA 90, shipowners, their P&I Clubs and their maritime lawyers usually co-operated fully with governmental agencies. But now, an early issue must be to clarify precisely whom the attorney will represent when contacted by the Coast Guard, the National Transportation Safety Board or any other governmental agency. Ordinarily, it is assumed the attorneys will represent the corporate owner and the individual crew members. Only rarely, in a situation where, for example, an officer is intoxicated, under the influence of drugs or acting recklessly, will the attorneys recommend that the officer obtain his own counsel. But situations requiring independent counsel can be expected to arise more frequently now that OPA makes it a crime to spill oil in a "grossly negligent" manner. In these circumstances, the owner and individual crew members may be exposed to possible criminal and civil liability.
Companies and individuals exposed to criminal prosecution must engage criminal defense counsel. Where appropriate, civil maritime lawyers might be well advised to involve criminal defense counsel early in the case in order to co-ordinate litigation strategy.
The Fifth Amendment to the Constitution of the United States provides that no one "shall be compelled in any criminal case to be a witness against himself." Invoking the privilege is consistent with innocence. As the Supreme Court has observed, "The privilege serves to protect the innocent who otherwise might be ensnared by ambiguous circumstances." But the privilege is deemed "waived unless invoked," and can be lost if a witness testifies voluntarily, unaware of the dangers and the loss of his or her rights. Moreover, once incriminating facts have been voluntarily revealed, the privilege cannot be invoked to avoid disclosure of further details.
The question, therefore, is when should a witness invoke his or her Fifth Amendment privilege? The simple answer is, the first time an incriminating question is asked, because failure to do so means the privilege is waived. Seafarers, including pilots, are required by law to report marine casualties to the Coast Guard or other maritime authorities. Seafarers, therefore, need to be very careful about what they say in such reports. For example, a pilot who reported a casualty (under pain of disciplinary action had he not done so) was held to have forfeited his Fifth Amendment privilege because he failed to invoke it in his original report.
It is increasingly important that attorneys should counsel their clients about the Fifth Amendment privilege against self-incrimination before their clients give evidence at a Coast Guard proceeding. Coast Guard investigating officers may feel obligated to turn over the results of an investigation to prosecutors if incriminating conduct has occurred -- even if the conduct is disclosed at an informal casualty proceeding.
Foreign seaman are also entitled to the protection of the Fifth Amendment when called to testify in proceedings before the United States Coast Guard, as well as before other Federal and state government bodies. Thus, it has been held that Japanese seamen could invoke Fifth Amendment rights in a Coast Guard hearing because any incriminating statements could be used against them in Japan.
Some attorneys recommend that clients invoke their Fifth Amendment privilege immediately after answering the so-called "pedigree" questions about name, address and place and date of birth. This is not meant to be disruptive, but only to safeguard the right of the witness.
On occasion, a witness can be granted immunity from prosecution. The witness must then testify. The procedure is as follows: the witness, upon being questioned, refuses to answer on the basis of the Fifth Amendment privilege. The presiding officer at the Federal proceeding then seeks an order of immunity from the Attorney General.
There are two separate types of immunity, "use" (or testimonial) immunity and "transactional" immunity. Use immunity protects a witness from having his or her testimony form the basis for a later prosecution of the witness. Transactional immunity, on the other hand, is much broader and protects the witness from any subsequent prosecution arising out of the same set of facts. Use immunity is more common. But distinguishing evidence given under use immunity from evidence obtained from other non-immunized sources is a procedural nightmare. Parties need to seek the advice of competent criminal defense counsel before venturing very far into this mine-field.
Procedures for obtaining immunity in state proceedings vary from state to state. In New York, for example, a witness called to testify before a grand jury has automatic immunity regarding such testimony. But in New Jersey, a witness must first invoke the Fifth Amendment privilege; upon doing so, the witness is taken before a judge who, after hearing from the state why the witness should be required to testify, will issue an order of immunity. As these procedures are quite different, maritime attorneys must work closely with local criminal defense counsel to safeguard the rights of mariners called to testify at state proceedings.
In addition to any immunity granted during a Federal or state proceeding, immunity may be conferred by statute. One such statute providing use immunity is the Federal Water Pollution Control Act (FWPCA). The purpose of the FWPCA's use immunity is to obtain quick reports about spills to facilitate prompt clean-ups. Immunity granted under the FWPCA provided the grounds for a successful appeal to the intermediate applicable court dismissing the criminal charges against Joseph Hazelwood, captain of the EXXON VALDEZ. However, the Alaska State Supreme Court recently reversed that holding and held that because of "inevitable discovery" Captain Hazelwood was not entitled to use immunity. OPA 90 has retained use immunity, though it has limited its application to "natural" persons. In other words, use immunity is no longer available (as it was under the FWPCA) to corporations, partnerships, associations, etc. (Ref. OPA 90 Sec. 4301 (a) (3)).
It is not uncommon for a civil action to be commenced immediately following a maritime casualty. In many cases, vessel owners themselves petition for limitation of liability. A witness in the limitation case can also become the target of criminal proceedings. If such a witness is subpoenaed to give a deposition in the limitation case, the witness should promptly move for a protective order postponing the civil deposition until termination of the criminal proceedings. If the witness were instead to testify at a deposition in the limitation case, the testimony would be deemed a waiver of the Fifth Amendment privilege.
Obviously, these are very significant and sensitive issues. Not only can a maritime attorney unexpectedly encounter a conflict of interest between a vessel owner and its crew, but the timing and manner of invoking a Fifth Amendment privilege can be critically important, as well as the scope of immunity obtained. It is essential that in an oil pollution incident, attorneys acting for owners should be quick to contact separate, competent criminal defense attorneys to protect the rights of their clients and to discharge their ethical duty to warn others to seek criminal defense counsel when appropriate.
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EXCESS OF LOSS REINSURANCE COVERAGE FOR ASBESTOS-RELATED
CLAIMS
by Robert
E. Wilder
Over the last few decades companies that manufactured, distributed or were otherwise involved with products containing asbestos have been subjected to billions of dollars of liability, primarily as a result of personal injury claims asserted by individuals who had contracted asbestos or cancer from the inhalation of asbestos fibers. Companies have also been compelled to pay substantial sums as compensation for the cost of removing asbestos insulation from vessels and buildings. These companies have sought indemnification for their asbestos-related losses from their insurers. Although the insurance industry has mounted an aggressive defense, the American courts have, for the most part, construed liability insurance policies so as to maximize coverage for asbestos-related claims. These insurers have, in turn, presented claims to their reinsurers.
A common form of reinsurance is excess of loss treaty reinsurance. With respect to covered classes of business an excess of loss treaty typically obligates the reinsurer to pay up to a stated sum for each accident, occurrence or event, in excess of a deductible (known as a "retention") for each accident, occurrence or event. The per accident retention is frequently quite large. While the asbestos-related losses of a given insured may amount to millions of dollars in the aggregate, these losses will be comprised of thousands of underlying claims and the loss settlement with any one claimant will generally not exceed the reinsured's per accident retention. Certain reinsurance contracts have a provision which permits the reinsured to aggregate the products liability losses paid under an insurance policy for purposes of satisfying the reinsurance retention. However, in the absence of such a clause, or if asbestos-related claims, other than products liability claims, are involved, it becomes necessary to determine what constitutes the accident, occurrence or event for reinsurance coverage purposes. To obtain any recovery, the reinsured may have to establish that all the underlying claims against its policyholder arose from a single accident, occurrence or event, and, as such, it need only absorb one retention, per year, under the treaty.
A typical definition of "accident" or "occurrence" in an excess of loss treaty is as follows:
The term accident or occurrence shall be understood to mean each and every accident or occurrence or series of accidents or occurrences arising out of one event (emphasis added).
This definition contemplates the possibility that an event may involve multiple accidents or occurrences. To determine what sort of happening will suffice as an event, however, it is important to consider the purpose of excess of loss reinsurance. Unlike other forms of reinsurance, it is intended to cover large, unanticipated losses, resulting from catastrophic events or happenings such as earthquakes or explosions. A London-based industry institute has stated that excess of loss reinsurance protects a reinsured "from the effects of a happening, sudden or very limited in time and unexpected." A Study of the Development of Excess of Loss Methods of Reinsurance 1 (Insurance Institute of London Advanced Study Group No. 148, 1969). See also Robert W. Hammesfar & Scott W. Wright, Law of Reinsurance Claims 154 (1994) ("[t]he reinsurance industry has always understood the concept to mean that the loss causing event must be limited in time and place and must be identifiable."). For example, if a number of individuals are injured in different locations as the result of a large explosion, all of the resulting losses would be considered to have arisen from one event. However, excess of loss reinsurance is not intended to cover a number of small, unrelated claims, even if in the aggregate they are financially catastrophic from the standpoint of the reinsured.
Since the asbestos-related bodily injury losses of an insured typically involve claims by thousands of individuals who were exposed to asbestos fibers under varying circumstances over the course of decades, reinsurers have argued that the claims do not arise from a single event. Reinsureds, on the other hand, have taken the position that these claims arise from one event such as the original insured's decision to use an asbestos-containing product or its continuing failure to warn of the dangers of asbestos. These reinsureds reason that an act or omission which is the common cause of multiple losses is an event, even if it is a remote cause that is not limited in time and space.
No court has decided what constitutes an accident, occurrence or event in the context of asbestos-related claims under the terms of an excess of loss reinsurance treaty. However, in a different context, the English Court of Appeal in B.F. Caudle & Others v. Sharp [1995] LRLR 433 (Eng. C.A.), recently considered the requirements for a happening to suffice as an event under excess of loss reinsurance treaties. Evans LJ concluded that a causal connection between the happening and the resulting losses is not sufficient. He found that there is also an implied limitation based on remoteness. Otherwise, historical events such as World War II or the Ice Age could be considered "events" for reinsurance claim purposes, an absurd result.
A number of arbitration panels have considered the issue of what constitutes an event for purposes of asbestos-related reinsurance claims and there has been no consensus. For example, in Sun Insurance Office Ltd. v. Mercantile & General Reinsurance Co. Ltd., (London Arb. 1992), the arbitration panel concluded that the mining and distribution of asbestos without warnings by the original insured was too remote to be regarded as an event under excess of loss reinsurance treaties. The panel found that each individual claimant's injury constituted a separate accident, event or occurrence. Similarly, in General Accident Ins. Co. v. American Reinsurance Co. (New York Arb. 1985), the panel concluded that, although a failure to warn can be a basis for the original insured's liability, it is not an event within the meaning of an excess of loss reinsurance treaty.
Other arbitration panels have reached the opposite conclusion. In a 1990 reinsurance arbitration, for example, the arbitrators found that the original insured's continuous failure to warn of the hazards of asbestos was the single event from which a multitude of asbestos-related claims arose.
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THE OPA 90 NATURAL RESOURCE DAMAGE
ASSESSMENT RULES
by John W. Wall
The National Oceanic and Atmospheric Administration (NOAA) has issued final Natural Resource Damage Assessment (NRDA) Rules for the determination of damages to natural resources and restoration of resources damaged by oil pollution. The NRDA Rules provide general guidance for trustees, acting on behalf of the federal, state and local governments and native tribal authorities, to assess the severity of damage caused by an oil spill, and to develop and carry out plans for remedial action.
The most important aspect of the NRDA Rules for shipowners is that they require the trustees to invite responsible parties to participate in the assessment process. By taking advantage of this provision and becoming involved early, in what the Rules call the "pre-assessment phase," counsel for a responsible owner can help assure that the trustees follow the best available scientific methods, while significant information is still capable of being gathered. This should reduce the risk of an owner facing an assessment or restoration plan grounded in "junk science," as has sometimes happened in the past. Also, an owner who in the past would have funded two sets of experts, his own, and (out of settlement funds) the Government's, now should need to pay for only one consulting expert in each discipline.
Restoration plans that provide for the acquisition or restoration of natural areas comparable to an area damaged by oil pollution usually are both more cost-effective and environmentally worthwhile than plans which seek to restore heavily polluted spots to their original or "baseline" condition. In recognition of the importance of such "alternate site" acquisition or restoration, the NRDA Rules explicitly provide for "scaling," that is, determining how large or pristine an alternate site need be acquired or restored to compensate for injury caused to the actual site by oil pollution.
While the Rules do not mention "contingent valuation" (i.e., where the value of resources is estimated by reference to public opinion surveys), neither do the Rules prohibit the use of contingent valuation methodology. Contingent valuation often has been criticized for its potential to lead to very large and speculative claims.
Given the great flexibility of the NRDA Rules, there can be no assurance that the trustees will follow an appropriate, scientific approach. However, if an owner participates actively in good faith in the assessment process, the prospect of a reasonable outcome should be enhanced greatly.
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EXXON V. SOFEC, INC., ET AL.
by John
C. Koster
A recent unanimous decision (June 10, 1996) of the United States Supreme Court clarified the relationship of various causation doctrines in the field of maritime law following the proportional fault doctrine announced in Reliable Transfer (decided in 1975). The Reliable Transfer case held that in cases of mutual fault, damages are to be allocated between the parties on a proportional fault basis (i.e., the liability of each party for the total damages suffered by all parties is proportional to each party's degree of fault in causing the loss). In the Exxon case the Supreme Court held that the proportional fault principle of Reliable Transfer does not preclude a finding that the plaintiff's own intervening negligence constituted a superseding cause entirely sufficient to account for all the damage and that in such circumstances no assessment of the relative degree of fault of both parties is necessary.
Exxon's vessel, the EXXON HOUSTON, was engaged in discharging to a single point mooring system (SPM) when a storm arose, causing the vessel to break away from the SPM at 1728 hours due to a defect in the mooring system. One of two parted discharge hoses remained affixed to the vessel and it took a considerable period of time with the assistance of a small vessel to neutralize the effects of the parted, but still connected, hose. The Trial Court had held, however, and the Appellate Court accepted as fact, that as of 1830 hours (a little over an hour later) the situation had reached a position of equilibrium, since the vessel was headed out to sea and was in no immediate danger stemming from any prior negligence or contractual breach by the defendants. The various defendants were the owners, operators and manufacturers of the SPM.
Thereafter, however, the Master of the EXXON HOUSTON (during a period in which further work was done to disconnect the hose from the EXXON HOUSTON) failed to plot routine fixes while the vessel drifted, and the vessel subsequently ran aground on a reef.
The Supreme Court held that the defendants were not liable in either contract or tort since the Plaintiff's conduct was alone sufficient to account for the damage and was, therefore, the sole proximate cause of the damage. The Court stated:
. . . . where the injured party is the sole proximate cause of the damage complained of, that party cannot recover in contract from a party whose breach of warranty is found to be a mere cause in fact of the damage. Although the principles of legal causation sometimes receive labels in contract analysis different from the proximate causation label most frequently employed in tort analysis, these principles nevertheless exist to restrict liability in contract as well. Indeed, the requirement of foreseeability may be more stringent in the context of contract liability than it is in the context of tort liability.
The Court held that damages are to be apportioned only between parties whose actions are found to be a direct, proximate cause of the loss. A party whose actions, even though negligent, merely set the stage for a subsequent loss to occur, do not qualify.
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CERTIFICATES OF FINANCIAL RESPONSIBILITY
It has recently come to our attention that a vessel was sold in American waters to buyers who did not possess a United States Certificate of Financial Responsibility (COFR). The sale took place off-shore and the purchaser or attorneys for the purchaser did not insure that on delivery the vessel would be in compliance with all laws in the jurisdiction in which it was located at the time of sale. Within hours of the transfer of title, the United States Coast Guard threatened to issue a citation to the vessel because of its failure to have on board a current Certificate of Financial Responsibility. Fortunately, with the timely intervention of the vessel's club, port agents and ourselves, and with the prompt assistance of the National Pollution Funds Center, a fine was averted.
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On July 16th, President Clinton granted U.S. citizens the right to sue foreign companies using American property seized by Cuba 35 years ago, but then suspended that right of action for at least 6 months. The law also permits the United States to deny visas to the executives of companies that "traffic" in property expropriated by Cuba since 1959. This provision reportedly has already been used to deny visas to several executives of British and Canadian companies and their families with shareholding interests in Cuban entities, and is sufficiently broad in scope to cover the foreign shareholders of Cuban companies that use nationalized property.
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On April 25, 1996, the U.S. District Court for the Eastern District of Virginia held in National Shipping Co. of Saudi Arabia v. Moran Trade Corp. of Delaware that a non-discharging tug, which the court had found to be the sole cause of an oil spill, was entitled to limit its liability under OPA to its OPA statutory limit ($500,000). In reaching this result, the court expressly rejected the innocent spilling vessel's argument that the tug was liable to reimburse it in full for its OPA damages, (which far exceeded the tug's OPA liability limit as a non-tank vessel), under the federal maritime law and under state common law and statutory provisions. This case is one of the first significant judicial decisions involving third party claims by the owner of a discharging vessel.
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A BREAKFAST AND PANEL DISCUSSION
WITH WOMEN IN MARITIME LAW AND INDUSTRY
At 7:30 a.m. on May 2, 1996, more than eighty people gathered at the Yale Club in New York City for a Breakfast and Panel Discussion with Women in Maritime Law and Industry. The event was attended by lawyers, industry representatives, and law students from all over the United States and from several European countries.
The six panel members, all distinguished women in the maritime field, spoke candidly about their experiences over the past few decades as maritime lawyers and in the maritime industry. These pioneering women delivered lively and often humorous remarks, yet the underlying message was poignant. While opportunities for women in the maritime field have improved dramatically in the last twenty years and there is no longer a barrier to entrance to the field, many reported that discrimination has not been entirely eliminated. Women attending the Breakfast expressed strong interest in similar gatherings in the future, and it is anticipated that another event will take place during the week of October 14, 1996.
The Panel members were Lizabeth L. Burrell, a partner at Burlingham Underwood LLP, Mary Jane Keriakos, a sole practitioner, Lucienne Carasso Bulow, Assistant Vice President of Continental Grain Company and an Arbitrator and Vice President of the Society of Maritime Arbitrators, The Honorable Rosemary A. Denson, U.S. Administrative Law Judge, U.S. Coast Guard, Debra J. Kossow, Senior Admiralty Counsel, Civil Division, U.S. Department of Justice, and Marilu Marshall, Senior Vice President and General Counsel, Cunard Line Ltd. Welcoming remarks were given by Evanthia Coffee, Healy & Baillie, who also moderated the event, and by Andrea J. Berger, President of the New York Women's Bar Association, who encouraged the formation of a Maritime Committee within the Women's Bar.
The event was organized by Healy & Baillie attorneys, Evanthia Coffee, Ellen FitzGerald, and Cathy Niarchos, with the assistance and support of the firm. To be placed on a mailing list for future events, please contact any of the above.
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Julie A. Pateman joined the Firm as an associate attorney in June 1996. She received her J.D. from Albany Law School in 1995 and graduated from Union College with a B.A. in 1991.
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It may be helpful to our friends and clients to know something about the organization of Healy & Baillie. The firm is managed by an Executive Committee, which is elected by the partners on a two-year cycle. John Kimball chairs the Executive Committee. The other members of the Executive Committee are Jack Greenbaum and Robert Shaw.
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HONORS
NICHOLAS J. HEALY RECEIVES AWARD
On June 12, 1996, Nicholas J. Healy received the Distinguished Service Award at the Seamen's Church Institute's annual awards dinner. The award was bestowed upon Mr. Healy for his "contributions to the maritime community and commitment to the highest ideals of safety, justice and humanitarianism." Other awards were presented at the dinner to Erik P. Johnsen of International Shipholding Corporation who received the Silver Bell Award, to the United States Coast Guard (accepted by Captain Thomas Gilmour, the Coast Guard Captain of the Port of New York) and to Maher Terminals, which celebrated its 50th Anniversary. Closing remarks were delivered by Vice Admiral Arthur E. Henn, Vice Commandant of the United States Coast Guard.
Over six hundred people attended the dinner on the Village Green on Governors Island and the benefit raised a record-breaking $100,000 for the Institute. The Rev. Peter Larom is the Executive Director of the Seamen's Church Institute and the Dinner Chairman was Richard T. du Moulin, Chairman and CEO of Marine Transport Lines.
The firm joins in congratulating Nick Healy for this well deserved award.
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ROBERT G. SHAW ELECTED PRESIDENT
OF THE HELLENIC- AMERICAN CHAMBER OF COMMERCE
At the annual general meeting of the Hellenic-American Chamber of Commerce held on May 3, 1996, Healy & Baillie partner Robert G. Shaw was elected President of the Chamber.
The Hellenic American Chamber was formed in 1947 to represent the interests of Greek shipowners buying Liberty and Victory ships from the U.S. government after World War II. The Chamber is a member of the European American Chamber of Commerce, which is made up of all of the chambers of commerce in the United States linked to the European Union.
The Hellenic American Chamber continues to have a large number of members drawn from the shipping industry; however its membership now includes many other businesses linked to Greece and the United States. The Chamber holds meetings for visiting Ministers and other government officials from Greece, as well conferences and seminars. In recent years it has organized conferences on the U.S. Oil Pollution Act of 1990, Raising Capital for Shipping in the International Securities Markets, and Safety At Sea. Speakers have included shipowners, representatives of shipowning organizations, P and I Clubs, ship financing banks, classification societies and investment banks. The Chamber's board has 30 members, who represent various businesses including shipping, real estate, construction, banking, petroleum refining, supermarkets and food distribution.
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HOWARD M. MCCORMACK ELECTED FIRST
VICE PRESIDENT OF THE MARITIME LAW ASSOCIATION OF THE UNITED STATES ON
MAY 3, 1996
Howard M. McCormack has been elected First Vice President of the U.S. Maritime Law Association. The Association has more than 3,600 members throughout the United States as well as overseas. Howard has previously served the Association as Membership Secretary, Secretary and Second Vice President.
Howard has also been honored by Tulane Law School in New Orleans in recent months. He was appointed the John W. Sims Distinguished Admiralty Practitioner in Residence in April 1996 and gave a series of lectures at the law school. He was also recently elected to the Board of Advisors of the Admiralty Law Institute at Tulane, joining fellow partners, Nicholas J. Healy and Gordon W. Paulsen, on the Board. In May 1996 he was a member of the faculty of the Tulane Law School Maritime Law Center and lectured on maritime arbitration in the United States at the meeting held in London on May 7-8, 1996.
MAINBRACE is intended to provide general information. The articles contained in MAINBRACE do not constitute legal advice. An analysis of the facts relating to a particular issue must be accomplished before legal advice can be given.
NOTE: "Mainbrace," our Firm's cable address, in nautical terminology means the brace or rope sustaining the main yard on a ship. The Staff of "Mainbrace" consists of Nicholas J. Healy, Gordon W. Paulsen, John C. Koster, Matthew A. Marion, Betty M. Waterman and Renee Kintzer.
New York Office: 29 Broadway New York, NY 10006-3293 Telephone: (212) 943-3980 Telecopier: (212) 425-0131 |
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New Jersey Office: 374 Millburn Avenue P.O. Box 599 06902-6987 Millburn, NJ 07041-0599 Telephone:(201) 384-2556 Telecopier:(201) 384-1081 |
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MAINBRACE
HEALY & BAILLIE
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NEW YORK, NEW YORK 10006-3293
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