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November 1995
Vol. 6, No. 3
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Contents
An Overview of the U.S. Legal System
by LeRoy Lambert
We are fortunate to deal with many clients and attorneys in other countries and often have the pleasure of visiting them in their home countries or hosting them here. They are never bashful about letting us know the latest "unbelievable" legal news from America. A large verdict here, punitive damages there, OPA 90 here, the state of Washington's regime there, the Simpson trial . . . the list goes on and on, or so it seems.
Even in our daily routine of giving advice to clients and attorneys in other countries, we find that what seems to them a straightforward problem involves a careful analysis of a host of preliminary questions relating to jurisdiction, forum, and choice of law. "Why is it so complicated?" we are asked. Indeed, the frustration is sometimes shared by our American clients.
In part, our system is complicated, and we easily take aspects of our system for granted, in particular its "federal" nature. At the same time, our clients and colleagues in other countries naturally try to force our explanation into categories and procedures of the systems with which they are familiar. Accordingly, we believe it helpful to provide a brief, simplified overview of the U.S. legal system.
A. State and Federal
In the United States, there are two sovereign court systems, federal and state, existing side by side.
The state "system" actually consists of fifty separate, sovereign systems, geographically coextensive with the given state. Each state has its own civil and criminal laws and a separate judiciary (including trial, appellate, and supreme courts) to administer them, with final appeal in certain, exceptional circumstances, to the (federal) United States Supreme Court. The jurisdiction of state courts is general. They adjudicate virtually any dispute brought to them, assuming they have personal jurisdiction and venue is proper and convenient. State courts follow their own procedural rules and substantive law, unless the court finds that the law of another state or federal substantive law governs the claims before it.
Under the federal system, the country is divided into numerous "districts," which are in turn under the supervision of eleven courts of appeal, and, ultimately, the Supreme Court of the United States. Some districts are coextensive with a given state (and can be geographically large, e.g., Colorado is one federal court district); some states are divided into two or more federal districts (and can be geographically small, e.g., the Southern District of New York comprises Manhattan and the northern suburbs). While the state courts have general jurisdiction, the federal courts' jurisdiction is limited. They may adjudicate only those matters which the Constitution and Congress have authorized. Nevertheless, there are cases over which the federal courts alone may exercise jurisdiction. The two most common examples in our practice are in rem arrests of vessels and maritime attachments.
Federal courts throughout the United States apply generally uniform rules of procedure and substantive law to the extent federal substantive law governs (although there are on occasion inconsistencies among the federal circuits' interpretations). If federal substantive law does not apply, then a federal court is obliged to apply the law of the state in which it is located, or the law of the state which may otherwise apply under choice of law principles.
NOTE: We are frequently asked to do "company searches." Our foreign clients are often surprised when we ask "Which state?" This is because corporations in the United States exist by virtue of the laws of a particular state. With a few minor exceptions, there is no such thing as a "United States" corporation; there are only New York corporations, Delaware corporations, etc. The public records regarding each corporation are kept by a "Secretary of State" in that state (not to be confused with the Secretary of State of the federal government in Washington). The information obtainable is usually less than that in the commercial registries of other countries. Another difference between our system and those in many other countries is that there is no list in the public records of persons with signatory power.
Since state courts are courts of general jurisdiction competent to hear practically any claim, the "subject matter" jurisdiction of the state court is rarely an issue. By contrast, this is an issue which must be considered by the parties and the court in each case brought in federal court. Indeed, this is one of the few matters which our judges are entitled to raise on their own initiative.
B. Subject Matter Jurisdiction in Federal Court:
To sustain jurisdiction in federal court, claims must fall within three categories: the suit is between parties of diverse citizenship and the amount in controversy exceeds $50,000 ("Diversity of Citizenship" jurisdiction), or the cause of action is within the admiralty and maritime jurisdiction ("Admiralty and Maritime Jurisdiction"), or arises under the laws of the United States ("Federal Question" jurisdiction).
1. Diversity of Citizenship:
Federal courts have jurisdiction of actions between "citizens of a State [of the United States] and citizens or subjects of a foreign state . . ." The idea is that a state court might favor its citizen over a citizen of another state or a foreign state and that the federal courts, whose judges are appointed for life, are less likely to manifest such parochialism.
2. Admiralty and Maritime Jurisdiction:
Based on the concern that maritime law should be uniform throughout the states, the Constitution provides that the federal courts shall adjudicate maritime disputes. This jurisdiction extends to claims based on maritime contracts or torts. However, the Constitution "saves to suitors" their right to proceed in state court. If a plaintiff with a maritime cause of action proceeds in state court, the state court must nevertheless apply federal maritime law, not local state law, to the dispute.
3. Federal Question Jurisdiction:
This jurisdiction is available if a claim arises under a federal statute.
C. Personal Jurisdiction:
If the court has jurisdiction (i.e., is competent to render a judgment) over the subject matter, it still may not render an enforceable judgment between the parties before it unless it has jurisdiction over these parties. Unlike subject matter jurisdiction, a defense of lack of personal jurisdiction may be waived. This issue arises in both state and federal courts. Natural persons can be subject to suit in any state where service is made. Corporations, however, present special problems. To be subject to personal jurisdiction in a state court or a federal court, a corporation must be present in the state where the court sits, "not occasionally or casually, but with a fair measure of permanence and continuity." With respect to corporations, the issue is typically said to be whether it is "doing business" in that state. Moreover, a corporation may be subject to jurisdiction in a particular state if the cause of action arises out of an act by the corporation in that state.
D. Venue:
Even though venue may be technically proper, a federal court may transfer an otherwise properly filed action to another district where the action could be tried more conveniently. If there is no such district, and, if the court concludes that the original district is inconvenient, it may dismiss the action under the doctrine of forum non conveniens. Normally, however, it will dismiss the action on this ground only if there is an adequate alternative forum and if the defendant agrees to allow the action to proceed there. Most states also have such a doctrine. In deciding "forum non" motions courts typically look to a variety of factors, such as the plaintiff's choice of forum; location of defendant(s), witnesses, documents, and evidence; the court's docket; the interest of the forum in the dispute; and the applicable law.
E. Choice of Law:
Assuming there is a court with subject matter jurisdiction, personal jurisdiction, and a case not otherwise subject to transfer on the basis of "forum non," the parties and court must still determine the applicable law. Our courts, whether state or federal, are often required to find and apply the law of some other state, foreign or domestic, in order to adjudicate a matter. Each state has its own rules for determining the applicable law.
If the cause of action is based on a maritime tort or contract, courts consider such factors as the place of the wrongful act or breach; the place of contracting; the law of the flag; allegiance or domicile of injured party; allegiance of shipowner; place of contract of employment; inaccessibility of foreign forum; law of the forum; and shipowner's base of operations, etc. These factors are not exhaustive, and "the significance of one or more factors must be considered in light of the national interest served by the assertion of . . . jurisdiction."
We take comfort in the fact that our colleagues in Europe now face similar problems as Europe moves towards economic unity. Where may an action be brought? Where should it be brought? Who can be made a party? Whose law applies? In this regard the American experience of 200 years may prove useful. In any event, we hope the above shows how important it is under our system to analyze such questions carefully at the outset. It is necessary not simply because one may gain a tactical advantage, but because a wrong decision could be fatal to a claim or its defense.
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Bankruptcy Court and Maritime Liens
by Howard M. McCormack
The United States Bankruptcy Court in New Jersey issued two opinions in identical cases on September 5, 1995, in which it concluded that the Bankruptcy Court was not the proper forum to determine the extent, validity or priority of maritime liens because the vessels in question were not part of the time charterer Debtor's estate pursuant to 11 U.S.C. § 54 - nor did the Court have in rem jurisdiction over the vessels. The case involved claims in bankruptcy against a Debtor-in-Possession, Companhia de Navegacao Maritima Netumar, d/b/a/ Netumar Lines, by Supplymen who had furnished stevedoring services and supplied bunkers in the New York area to vessels under time charter to the Debtor. The Debtor did not contest the quantum of the claims. After the Debtor filed for Chapter 11 protection, the time charters were terminated. Subsequently, the vessels were sold to third parties. The original vessel owners filed claims in the bankruptcy proceedings seeking payment of outstanding charter hire and asserting other claims arising under the time charters.
ARREST IN SPAIN
In early 1995, some eleven months after the commencement of the U.S. bankruptcy proceedings, both vessels involved (now under new ownership) were seized in Spain by the Supplymen seeking to enforce their claims for maritime liens. The actions in Spain were filed pursuant to the provisions of the 1952 Arrest Convention to which Spain, but not the United States, is a signatory. Both vessels were released after security was posted. The Supplymen in the Spanish proceedings were directed to proceed in a court of competent jurisdiction to prove their claims against the vessels.
U.S. COURT PROCEEDINGS
The Supplymen, already claimants in the U.S. bankruptcy proceeding, filed adversary complaints in the bankruptcy court alleging that their actions were commenced to determine the validity, priority or extent of their lien or other interest in the Debtor's property. The claims against the Debtor were for services the Debtor had ordered for the benefit of the vessels. The Supplymen sought a judgment in the Bankruptcy Court for the amount of their claims in order to proceed in rem in Spain against the vessels and to collect against the bond posted there by the new owners to secure the release of the vessels. Subsequently, the Supplymen moved for summary judgment in the United States proceeding.
POSITION OF OWNERS
The former owners of the vessels, also claimants in the U.S. Bankruptcy Court, filed an opposition to the motions, arguing that the Bankruptcy Court had no jurisdiction to consider the application of the Supplymen because the Court did not have in rem jurisdiction over the vessels. The former owners argued that even if the Court found that the Debtor owed the amounts claimed, the Supplymen's real intent was to convert such a finding into an in rem claim against the vessels in the Spanish Court (even if the U.S. Bankruptcy Court did not specifically address such issues).
The Supplymen argued that the vessels and the Debtor became joint and several debtors, and, therefore, that the Supplymen had a maritime lien against the vessels arrested in Spain. The Supplymen tried to convince the U.S. Bankruptcy Court that an in personam judgment against the Debtor would convert the in personam right in the United States to an in rem finding for use in Spain against the vessels.
OPINIONS OF THE COURT
In two essentially identical opinions, the U.S. Court rejected the approach of the Supplymen. The Court found the vessels had been sold to separate and distinct owners who were not before the Court. The Court stated that the heart of the matter was whether it had jurisdiction to determine the nature and extent of any alleged maritime liens. The Court found it could inquire into its own jurisdiction, even sua sponte, but held that it would "not address the issue of the validity, nature, and extent of the maritime lien because this Court concludes that it is without jurisdiction to hear the matter."
The Court found the Debtor's relationship to the vessels at the time of the bankruptcy filing was that of a time charterer. Hence, the Debtor did not have title to or possession of the vessels, and the Court was without jurisdiction to render a decision with respect to the vessels.
In considering its jurisdiction to hear matters arising under or related to a Chapter 11 Proceeding under 28 U.S.C. § 157(b)(1), the Court considered the precepts of Title 28 U.S.C. § 1334(e) granting the United States Bankruptcy Court jurisdiction, under Title 11, over all property of the Debtor wherever located. Bankruptcy courts use this statute to determine the validity and extent of maritime liens when a lien is asserted related to property of the Debtor or the estate. Merely because the Bankruptcy Court may decide, under Section 157, that such a determination is a core proceeding does not end the matter because the dispute must be connected in some way to property of the Debtor or the Debtor's estate.
The Bankruptcy Court, as a court of limited jurisdiction, could not exercise jurisdiction over claims which involve neither the Debtor as a party nor assets or liabilities of the Debtor's estate. The Bankruptcy Court would not determine the validity, nature or extent of the maritime lien claimed by the Supplymen because such a determination would involve a claim against the vessels in rem and affect the rights of the current owners who were not before the Court. The Court, therefore, held it did not have jurisdiction to consider the maritime lien issues because such issues did not involve the Debtor as a party. In re Arctic Enters, Inc., 68 B.R. 71, 76 (D. Minn. 1986).
The U.S. Bankruptcy Court stated that in order to determine whether each vessel was part of the Debtor's estate, as required by Arctic, supra, it must first analyze maritime law and the Court referred to the leading decision of In re Riffe Petroleum Co. v. Cibro Sales Corp., 601 F.2d 1385, 1389 (10th Cir. 1979). In Riffe, the Court held that where the Debtor's relationship to the vessel at the time the bankruptcy petition was filed was that of a time charterer, the Debtor did not have title to or possession of the vessel; and, therefore, the vessel was not within the Bankruptcy Court's summary jurisdiction. Even though Riffe was decided under the Bankruptcy Act of 1898, the Court believed the analysis was still applicable. The Court concluded "in other words, as articulated in this district, 'a bankruptcy court should not assume jurisdiction over a matter that does not involve administration or property of a bankrupt estate'." Matter of Elsinore Shore Assocs., 66 B.R. 708, 713 (Bankr. D.N.J. 1986).
CONCLUSION
This is the latest case in which U.S. bankruptcy courts continue to discuss their limited jurisdiction, particularly when claims are made against vessels not within or subject to the jurisdiction of the court and which are not the property of the Debtor's estate.
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Seaman Status: In the Eye of the Beholder
by Andrew V. Buchsbaum
T. Between 1958 and 1991, the United States Supreme Court maintained its silence in the midst of increasing confusion in the lower courts regarding the precise definition of seaman status under the Jones Act, 46 U.S.C. § 688. In an unprecedented burst of activity, the high court has issued three major opinions in the last five years, seeking to better define this "most gallant but improvident class of men." (Story, J., in Reed v. Canfield, 20 F. Cas. 426, 428 (D. Mass. 1832)).
Although the Jones Act provides the legal framework for negligence actions at law by "seamen," Congress failed to define the term, instead allowing courts to wrestle with the issue. Since the enactment of the Jones Act in 1920, the lower federal courts, with surprisingly little guidance from the Supreme Court (other than that the issue is normally one for a jury), have struggled mightily, leading one court to remark that "we have made a labyrinth and got lost in it. We must find our way out." Judge Harlington Wood, Jr. in Johnson v. John F. Beasley Construction Co., 742 F.2d 1054, 1061 (7th Cir. 1984). See also Burks v. American River Transportation Co., 679 F.2d 69, 75 (5th Cir. 1982), where in a related context, the late Judge John R. Brown remarked that "[n]o doubt the three men in a tub would also fit within our definition, and one probably could make a convincing case for Jonah inside the whale."
After 33 years of silence on the issue, the Supreme Court reentered the mire with vigor in 1991, first deciding McDermott International Inc. v. Wilander, 498 U.S. 337 (1991). Wilander provided a liberal interpretation of seaman status by "jettison[ing] the requirement that a seaman 'aid in navigation' of a vessel, instead holding that a seaman must merely 'perform the work of a vessel.' " Later that year, in Southwest Marine, Inc. v. Gizoni, 502 U.S. 81 (1991), the Court continued its expansive reading of seaman status by concluding that an employee engaged in an activity specifically enumerated under the Longshoreman's and Harbor Workers' Compensation Act could still qualify as a Jones Act seaman if he had the requisite connection to a vessel.
Finally, in Chandris, Inc. v. Latsis, 115 S.Ct. 2172, 132 L.Ed.2d 314 (1995), the Supreme Court returned to an issue raised but not discussed in Wilander, namely what "employment-related connection to a vessel in navigation is necessary for a maritime worker to qualify as a seaman under the Jones Act." Respondent Latsis was employed as a superintendent engineer responsible for maintaining and updating electronic and communications equipment on board petitioner's fleet of six passenger vessels. Part of his job was performed on board vessels at sea, and part on board a vessel in drydock. Latsis claimed he spent 72% of his time at sea, while his immediate supervisor claimed it was closer to 10%. The Supreme Court required that a seaman "must have a connection to a vessel in navigation (or to an identifiable group of such vessels) that is substantial in terms of both its duration and its nature." As guidance, the Court acknowledged the Fifth Circuit's "rule of thumb" that requires a seaman to spend more than 30% of his time in the service of a vessel. The case was remanded for a jury determination of seaman status, including whether time spent by the vessel in drydock should be included in the Jones Act equation.
In sum, it appears the Supreme Court once again will distance itself from determinations of Jones Act seaman status by requiring a jury to determine the issue in cases where "reasonable persons, applying the proper legal standard, could differ as to whether the employee was a member of a crew." By providing a definitive jury instruction at long last, the Supreme Court has ensured that its wisdom on the subject will most likely not be heard for many years to come. However, given the continued vagaries of the newly revised legal formulation, coupled with the peripatetic nature of life at sea, it appears the lower courts will continue to flounder with the concept.
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Direct Action - P&I Club Morewitz v. West of England Ship Owners Mutual
Protection and Indemnity Association (Luxembourg), 62 F.3d 1356 (11th Cir.
1995).
by John W. Wall
In a wrongful death action arising from the loss of the M/V IMBROS on the high seas on a voyage from Mobile to Quebec in 1975, the Court of Appeals for the Eleventh Circuit held the vessel owners' P&I Club subject to suit, even though plaintiff's action against the Cypriot owners was dismissed for lack of personal jurisdiction many years ago by a Virginia federal court. The Virginia court awarded damages as a discovery sanction against the vessel's managers, whom the court found to be the "owners," but the managers became insolvent and now are defunct. Plaintiff subsequently sued the Club in Alabama federal court under a state statute giving a judgment creditor the right to proceed against the judgment debtor's insurer. Although the Club did not insure the vessel's managers, the court denied the Club's motion to dismiss. Alternatively, the Club sought to stay the action pending London arbitration, as provided for in the Club's insurance contract with the owners, but the Eleventh Circuit held that the Club had waived its right to arbitrate by failing to demand arbitration against the uninsured managers during the Virginia proceeding, to which the Club was not a party and during which no claims were asserted directly against the Club.
It is understood that the West of England will petition the United States Supreme Court for a writ of certiorari to review the decision. Arguably, the Eleventh Circuit may have given the Alabama statute an unconstitutional interpretation, since the U.S Constitution limits the power of states to regulate foreign commerce and expressly prohibits state legislation "impairing the Obligation of Contracts." Despite this action's confused and lengthy procedural history in two different federal circuits, it is possible the Supreme Court might review the decision due to its impact on international commerce and its conflict with the policy of recognizing agreements to foreign arbitration announced by the Court on June 19, 1995 in Vimar Seguros y Reaseguros v. M/V Sky Reefer.
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Coast Guard Revamps Vessel Registry
by Glen T. Oxton
Last August the Coast Guard revised the United States flag vessel registry (which is referred to in the statute as "documentation"). All records of documentation and the place for submission of all instruments for recordation have been centralized at the National Vessel Documentation Center (the "NVDC"). The NVDC is located at 2039 Stonewall Jackson Drive, Falling Waters, West Virginia 25419; telephone: 800-799-8362; facsimile: 304-271-2400.
The old system, which was in effect for many years, was based upon a decentralized "home port" arrangement. Formerly, a home port had to be declared for every vessel. In most cases, a vessel's home port was the city of the Coast Guard documentation office for the Coast Guard district in which the owner was domiciled. There were fourteen possible home ports.
A vessel's original Abstract of Title was maintained at its home port, and all applications to the Coast Guard concerning documentation as well as all instruments affecting the vessel had to be filed at its home port. Anyone wishing to know the name of the owner of a vessel or the liens recorded against it would first have to ascertain the vessel's home port. Then a request could be made to the Documentation Officer at that home port for the appropriate certificates.
By centralizing vessel documentation, the Coast Guard was able to phase out the fourteen separate home port offices and consolidate their operations at the NVDC. The Coast Guard expects to obtain increased efficiency by consolidating the offices. In the past, for example, staff members at some home ports would be overwhelmed with their volume of work, while in other ports the staff members were idle. In addition, centralization will make it easier to place vessel records into a computerized system and to offer other automated services.
In order to ameliorate the inconvenience of having to file all instruments in West Virginia, the Coast Guard also authorized filing of documents by facsimile. Documents filed by facsimile are valid for ten days, within which the manually signed original document must be delivered to the NVDC. If the original bears any material alteration from the copy received by facsimile, the Documentation Manager will reject the filing obtained by facsimile and deem the modified original document to be a new filing. The consequences of a rejected filing are discussed below.
Several years ago, in order to alleviate backlog problems at some of the Home ports, the Coast Guard initiated a two-step procedure for recording documents. Under this change, when an original document was delivered to a Documentation Officer at a Home port, it was stamped with the date and time of receipt. All documents were stamped in the order in which they were received, and when they were stamped they were considered filed. The Coast Guard then processed the document by reviewing it as to form. If the form was acceptable, the document was recorded in the appropriate book, and the recordation was noted on the vessel's original Abstract of Title. This process might not be completed until several months after the filing.
If the document passed the Documentation Officer's scrutiny, it was given effect as a mortgage, lien or transfer as of the time of filing. If the document was rejected by the Documentation Officer, the person offering it was given ninety days within which to correct or supplement the original filing in order to obtain an effective date as of the time of filing. A rejected document that was incapable of being corrected, or was simply not corrected, would result in a cancellation of the filing. When a filing is canceled it is retroactively nullified for all purposes.
The two-step procedure is being continued under the new structure. Home ports, however, are things of the past. The regulations still require that owners designate and mark their vessels with a hailing port, but provide no guidance other than requiring it to be one of the U.S. cities listed in an information processing publication of the Department of Commerce. The Manager of the NVDC is authorized to "settle disputes" as to the propriety of the hailing port designation. Presumably, if the owner's domicile is used as the hailing port, it will not be disputed.
The centralization of documentation services is a positive step that will potentially provide better service to the maritime and recreational boating industries. Eventually, there may even be online access to vessel documentation records. For the time being, however, the NVDC appears to be undergoing a transition period during which it is nearly impossible to contact them by facsimile or telephone.
The amendments to the regulations are contained in 60 Federal Register 31602, June 15, 1995, and 60 Federal Register 40238, August 7, 1995.
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Following implementation of the COFR requirement under OPA 90, the United States Coast Guard has developed a generally efficient system for processing COFR applications. Once an application has been filed the turnaround time at the National Pollution Funds Center often amounts to less than a week.
Nonetheless it sometimes takes more than a few days for owners to assemble the requisite information for, and signatures on, the Coast Guard COFR application form (CG 5585). Some owners with vessels chartered out under time charter, have filed CG 5585s in advance. If the time charterer thereafter designates a U.S. port, one of the essential steps has already been accomplished. However, Owners obviously do not want to pay for the cost of a financial guarantee unless Owners are certain the vessel will actually be sent to the United States.
If the Coast Guard receives a CG 5585 form without the accompanying financial guarantee, the Coast Guard will normally send a notice, a second notice and a third notice at thirty day intervals, following which the Coast Guard will regard the application as withdrawn. We are advised, however, that while the Coast Guard is not required to do so, and does not encourage unnecessary filings, the Coast Guard on request will hold a filing for a year even though unaccompanied by a financial guarantee. A guarantee must thereafter be provided (if the vessel is sent to the United States). Otherwise, the Coast Guard will delete the COFR application from its database and require the submission of a new CG 5585 form.
Vessel owners and operators with any questions concerning COFRs can call John Koster or Matthew Marion at the Firm.
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The Firm is pleased to announce that Michael J. Murphy and Robert E. Wilder became members of the Firm on July 1, 1995. Michael Murphy was a partner at Lord Day & Lord, Barrett Smith from 1976 to September 1994 when Lord Day dissolved. He was then briefly a member of the firm of Morgan, Lewis & Bockius.
Michael's practice is concentrated in insurance and reinsurance related matters, including the representation of major American and English reinsurers. He has also been active in the representation of various Liquidators of insolvent Bermudian insurers and reinsurers. His practice also has involved a substantial amount of professional liability work involving law firms, accountants and brokers.
Robert Wilder has worked closely with Michael since 1980 as an associate at Lord Day & Lord, Barrett Smith and at Morgan, Lewis & Bockius. He specializes in complex business litigation with an emphasis on insurance, reinsurance, liquidation and professional liability matters.
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Healy & Baillie's Connecticut office opened on September 1, 1995, with John W. Wall the resident partner. The office is located in the north tower of Stamford Harbor Park, on a tributary of Long Island Sound near the Stamford railroad station and Interstate 95. Six of our lawyers are now admitted to practice in the Connecticut state courts, and nine in the Connecticut federal court. The Connecticut office is closely integrated with the main office in New York, and attorneys working in the Connecticut office have full electronic access to the firm's computer network.
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Ellen M. Fitzgerald joined the Firm as a full-time associate in February, 1995. Ellen is a graduate of Yale University. She received her J.D. from the University of Connecticut in 1990. Ellen was formerly an associate with the firm of Burlingham Underwood.
Catherine N. Niarchos joined the Firm as a full-time associate in June. She received an LL.M. in 1994 from Columbia University School of Law, a J.D. in 1986 from the University of California, Hastings College of the Law, and a B.S.F.S. in 1980 from Georgetown University, School of Foreign Service. She has worked as a law clerk for the United States Court of International Trade and the United States District Court for the Northern District of New York, and in private practice.
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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 |
Hong Kong Office: Luk Hoi Tong Bldg., Suite 1301 31 Queen's Road Central Hong Kong Telephone: (852) 2 537-8628 Telecopier: (852) 2 521-9072 |
Connecticut Office: Stamford HarborPark 333 Ludlow Street Stamford, CT Telephone: (203) 961-7250 Telecopier: (203) 357-7909 |
New Jersey Office: 374 Millburn Avenue P.O. Box 599 06902-6987 Millburn, NJ 07041-0599 Telephone:(201) 384-2556 Telecopier:(201) 384-1081 |
Internet:Reception@Healy.com
MAINBRACE
HEALY & BAILLIE
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NEW YORK, NEW YORK 10006-3293
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