Supre
42
REPLY.
Hongda
In the Vice Admiralty Court of
Üdv
[Title of Action.]
The Plaintiffs deny the several statements contained in the Answer and Counter-claim [or, as the case may be].
Dated the
day of
(Signed)
18
A B. &c., Plaintiffs.
(2.) In an Action for Salvage:
Supreme
a. (The "Crosby.")
PETITION.
In the Vice Admiralty Court of
Adira?
[Title of Action.]
Writ issued
18
1. The "Asia" is an iron screw steam ship of 902 tons net register tonnage, fitted with engines of 120 horse-power nominal, is of the value of £15,000, and was at the time of the services herein-after stated manned with a crew of twenty-three hands under the command of George Hook Bawn, ber master.
2. At about 9 a.m. on the 29th of April 1877, while the Asia -which was in ballast proceeding on a voyage to Nikolaev to load a cargo of grain-was between Odessa and Ochakov, those on board her saw a steam ship ashore on a bank situated about ten miles to the westward of Ochakov, The "Asia" imme- diately steamed in the direction of the distressed vessel which made signals for assistance.
3. On nearing the distressed vessel, which proved to be the "Crosby," one of the "Asia's" boats was sent to the "Crosby," in charge of the second mate of the "Asia," and subsequently the master of the "Crosby" boarded the "Asin," and at the request of the master of the "Crosby" the master of the "Asia' agreed to endeavour to tow the "Crosby" afloat.
"
4. The Crosby" at this time was fast aground, and was lying with her head about N.N.W.
5. The master of the "Asia" having ascertained from the master of the "Crosby" the direction in which the "Crosby" had got upon the bank, the "Asia" steamed up on the starboard side of the "Crosby" and was lashed to her,
6. The "Asia then set on ahead and attempted to tow the Crosby" afloat, and so continued towing without effect until the hawser which belonged to the "Asia" broke.
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7. The masters of the two vessels being then both agreed in opinion that it would be necessary to lighten the "Crosby" before she could be got afloat, it was arranged that the cargo from the "Crosby" should be taken on board the "Asia."
8. The "Asia" was again secured alongside the " Crosby" and the hatches being taken off cargo was then discharged from the "Crosby" into the "Asia," and this operation was con- tinued until about 6 p.m., by which time about 100 tons of such cargo had been so discharged.
9. When this had been done both vessels used their steam, and the "Asia" tried again to get the "Crosby" off, but without success. The "Asia" then towed with a hawser ahead of the "Crosby," and succeeded in getting her afloat, upon which the "Crosby" steamed to an anchorage and then brought up.
10. The "Asia" steamed after the "Crosby" and again hauled alongside of her and commenced putting the transhipped cargo again on board the "Crosby," and continued doing so until about 6am. of the 30th of April, by which time the operation was completed, and the "Crosby" and her cargo being in safety the "Asia" proceeded on her voyage.
11. By the services of the Plaintiffs the "Crosby" and her cargo were rescued from a very dangerous and critical position, as in the event of bad weather coming on whilst she lay aground she would have been in very great danger of being lost with her cargo.
12. The "Asia" encountered some risk in being lashed along- side the " Crosby," and she ran risk of also getting aground and of losing her charter, the blockade of the port of Nikolaev being at the time imminent.
13. The value of the hawser of the "Asia" broken as herein stated was F400.
*
14. The "Crosby" is an iron screw steam ship of 1,118 tons net (1,498 gross) register tonnage. As salved the "Crosby and her cargo and freight have been agreed for the purposes of this action at the value of £41,092.
The Plaintiffs claim-
1. Such an amount of salvage, regard being had to the said
agreement, as the Court may think fit to award.
2. The condemnation of the Defendants [and their bail] în
the salvage and in costs.
3. Such further and other relief as the case may require.
Dated the
day of
(Signed)
18
A.B., &c., Plaintiffs.
ん
201
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