Plaintiff: Buggy Fix Repairs Pte Ltd

Admiralty in Rem No. [] of 2014

BETWEEN
BUGGY FIX REPAIRS PTE LTD
Plaintiffs
AND
The Owners and/or Other Persons Interested in the Ship or Vessel MV MICKHERSON
Defendants
AFFIDAVIT
I, [name of deponent] of [place of residence or work place] make oath/affirm and say as
follows:
1.

I am a manager in the company of the Plaintiff of [address] and I make this affidavit on
its behalf. Save as is hereinafter expressly stated, the matters to deposed herein are within
my knowledge or in accordance with my instructions from the Plaintiff and documents
supplied to me by the Plaintiffs. Insofar as the matter deposed to herein are within my
own knowledge they are true and insofar as they are in accordance with my instructions
or derived from statements or documents which I have read as hereinafter appears, they
are true to the best of my knowledge and belief

2.

The Plaintiff is a company incorporated in the Republic of Singapore and carry on

business as ship repairers in Singapore

3.

I am informed by [name], managing director of the Plaintiffs and believe that the
Plaintiffs effected repairs to the Defendants ship or vessel MV MICKHERSON in
Singapore between [] September 2012 and [] September 2012 at the request of
MASTERS CHAMP MANAGEMENT INC the Defendants manager.

4.

The Plaintiffs charges and disbursements for the said repairs amount to the sum of
US$3.0 million, of which US$1.0 million has been repaid, and the sum of US$2.0 million
remains due and owing to the Plaintiff. This is despite the Plaintiff having agreed to 5
monthly repayments of the said sum.

5.

The nature of the property to be arrested is the ship or vessel MV MICKHERSON of

the port of [].

6.

The ship or vessel MV MICKHERSON is the ship against which the action is brought
and is the ship in connection with which the claim in the action arose.

7.

In my belief, the party who would be liable on the claim in an action in personam is PHIL
AMY SA.

8.

In my belief, PHIL AMY SA was when the case of action arose the owners of the ship or
vessel MV MICKHERSON. The grounds for my belief are as appears from Lloyds
Register of Shipping for 2006 that the owners of the ship or vessel MK
MICKHERSON is stated as [] of [].

9.

In my belief, [] were on [] September 2012, the beneficial owners of all the shares in the ship
or vessel MV MICKHERSON. The grounds for my belief are as appears from Lloyds
Register of Shipping for 2006 that the owners of the ship or vessel MK
MICKHERSON is stated as [] of []. A copy of Lloyds Register of Shipping shows that no
change of ownership has taken place since the cause of action arose.

10.

Pursuant to a clause in the repair contract, the Plaintiff has commenced arbitration
proceedings in England on [] March 2013, and the tribunal has been constituted but no
pleadings have been served.

11.

In March 2013, the presiding judge sitting in the English High Court discharged a Mareva
injunction against the owner PHIL AMY SA which he had initially granted, as he found
that there was no real evidence of risk of dissipation.

SWORN/ AFFIRMED in [] )
By the abovenamed [] )
[name of deponent]

On this [] day of [] 2014 )

Before me,

A COMMISSIONER FOR OATHS