Professional Documents
Culture Documents
John Richards and Wendy Richards, husband and wife, are adult individuals who
reside in Bonita Springs, FL and at all material times hereto were the owners of a yacht named
the Windermere.
2.
laws of the State of Delaware with a principal place of business located at 436 Walnut Street, in
Philadelphia, PA.
3.
Ace provided property damage insurance to John and Wendy Richards for their
4.
the laws of Connecticut with its main office at 170 Canal Street, Plantsville, CT.
5.
At all times material hereto, the JUDY M, a tug, was owned and operated by the
6.
7.
On or about November 15, 2013, Mr. Richards was aboard his yacht,
Mohawk had been hired to tow the Windermere to Brewer Cove Haven Marina in
10.
During the towing operations, due to the negligence of the Judy M, the Judy M
struck and collided at least three times with the Windermere, causing damage to the Windermere.
11.
Ace has partially compensated Mr. and Mrs. Richards for their property damage
to the Windermere, and is subrogated, to the extent of its payments, to the rights of Mr. and Mrs.
Richards.
COUNT I
GENERAL MARITIME LAW- NEGLIGENCE
12.
Plaintiffs hereby incorporate by reference each and every allegation set forth
The property damages sustained by Mr. and Mrs. Richards were no fault of their
own, but were caused by the negligence of the Defendant in that the Defendant had a duty to
avoid collisions by maintaining the Judy M in safe operating condition, and operating the Judy M
in a safe manner and in compliance with the Rules of Navigation.
14.
The Defendant breached its duties by failing to properly maintain and operate the
Under Count I, that this Court enter judgment in favor of Mr. and Mrs. Richards
Respectfully submitted,
A
w J. So tes, Jr., sq. (ct-26963)
Law Offices of David W. Rubin
600 Summer Street, Suite 201
Stamford, CT 06901
Telephone: (203) 353-1404
Facsimile: (203) 357-7208
Email: ajsoltes@dwr-law.com
OF COUNSEL:
COZEN O'CONNOR
William N. Clark, Jr., Esquire
1900 Market Street
Philadelphia, PA 19103
(215) 665-4101
(215) 665-2013 - fax
wclark@cozen.com
Attorneys for Plaintiffs