SSA Terminals, LLC et al v. M/V Micronesian Nations et al Doc.

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Case 3:05-cv-02751-JSW Document 18 Filed 07/21/2005 Page 1 of 3

1 RUSSELL, MIRKOVICH & MORROW

Joseph N. Mirkovich, SBN.: 45644
2 Margaret E. Morrow, SBN.: 145306
Anne M. Grignon, SBN.: 230355
3 One World Trade Center, Suite 1450
Long Beach, California 90831-1450
4 (562) 436-9911 / fax: (562) 436-1897
5 Attorneys for Plaintiff SSA Terminals, LLC,
Coast Maritime Services, Inc. and Shippers Transport Express, Inc.
6
7
8 UNITED STATES DISTRICT COURT
9 NORTHERN DISTRICT OF CALIFORNIA
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11 SSA TERMINALS, LLC, COAST ) CASE NO.: C05-2751 JSW
MARITIME SERVICES, INC AND )
12 SHIPPERS TRANSPORT EXPRESS, ) IN ADMIRALTY
INC. )
13 ) JOINT STIPULATION FOR
Plaintiffs, ) APPLICATION FOR RELEASE OF
14 ) VESSEL M/V MICRONESIAN
vs. ) NATIONS AND [PROPOSED]
15 ) ORDER
M/V MICRONESIAN NATIONS, her )
16 tackle, apparel, etc., in rem; P M & O )
Line and Does 1 through 20, inclusive, )
17 in personam )
)
18 Defendants. )
)
19
20 Plaintiffs SSA TERMINALS, LLC, COAST MARITIME SERVICES,
21 INC. AND SHIPPERS TRANSPORT EXPRESS, INC. and Defendants M/V
22 MICRONESIAN NATIONS, her tackle, apparel, etc., in rem and P M & O Line,
23 by and through their respective attorneys of record, have agreed to the following:
24
25 1. Plaintiff has received payment from the vessel owners for those
26 charges underlying its complaint in this action.
27
28 2. All costs due to the Clerk have been paid and all fees and
-1-
JOINT STIP FOR APP FOR RELEASE OF VESSEL M/V MICRONESIAN
NATIONS AND [PROPOSED] ORDER
Dockets.Justia.com
 Case 3:05-cv-02751-JSW Document 18 Filed 07/21/2005 Page 2 of 3

1 disbursements due the U.S. Marshal in this action have been paid or provided for.
2
3 3. Accordingly, Plaintiffs SSA TERMINALS, LLC, COAST
4 MARITIME SERVICES, INC. AND SHIPPERS TRANSPORT EXPRESS, INC.
5 and Defendants M/V MICRONESIAN NATIONS, her tackle, apparel, etc., in
6 rem and P M & O Line, by and through their respective attorneys of record,
7 requests this Court to Order the release of the M/V MICRONESIAN NATIONS
8 from arrest forthwith.
9
10
11 Dated: July 20, 2005 RUSSELL, MIRKOVICH & MORROW
12
13 By: /s/
Anne M. Grignon, Esq.
14 Attorneys for Plaintiffs SSA Terminals,
LLC, Coast Maritime Services, Inc. and
15 Shippers Transport Express, Inc.
16
17
18 Dated: July 20, 2005 BINGHAM McCUTCHEN, LLP
19
20 By: /s/
(signed with permission)
21 C. William Craycroft, Esq.
Attorneys for Defendant
22 M/V MICRONESIAN NATIONS
and P M & O LINE
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JOINT STIP FOR APP FOR RELEASE OF VESSEL M/V MICRONESIAN
NATIONS AND [PROPOSED] ORDER
 Case 3:05-cv-02751-JSW Document 18 Filed 07/21/2005 Page 3 of 3

1 [PROPOSED] ORDER
2 IT IS HEREBY ORDERED that the M/V MICRONESIAN NATIONS be
3 released from arrest by the U.S. Marshal forthwith and the U.S. Marshal is
S DISTRICT
4 exonerated from all liability therewith. ATE C
T

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5 ERED

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6 lsup
illiam A

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July 21, 2005 N C
F
D IS T IC T O
8 Dated: R
U.S. DISTRICT COURT JUDGE
9 F:\WP51NET\DOCS\SSA\STEVE-140\pleading\dismissal.release.wpd

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JOINT STIP FOR APP FOR RELEASE OF VESSEL M/V MICRONESIAN
NATIONS AND [PROPOSED] ORDER