Pham v. F/V St Joseph VII

Filing 1

COMPLAINT For Arrest and Demand for Security against F/V St Joseph VII, filed by Cong Pham. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit A, # 3 Exhibit B, # 4 Affidavit)(Crew, Paxton) Modified on 12/27/2011 (pkb, ).

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
BEAUMONT DIVISION
Cong Pham
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Plaintiff,
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§
v.
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§
Civil Action No.
F/V ST JOSEPH VII,
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In Admiralty Rule 9(h)
official no. 1139728 and any
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freights, apparel, appurtenances, tackle, etc. §
in rem
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VERIFICATION AND AFFIDAVIT PURSUANT TO ADMIRALTY RULE C
My name is Paxton N. Crew, I am an attorney of record for Cong Pham, and I am capable of making
this statement. I have read the above and foregoing Complaint and the allegations thereof are true
and correct based upon the information, knowledge and belief, based on my personal knowledge
and on information and documents furnished by or on behalf of plaintiff. Additionally, attached to
the complaint are true and correct copies of the correspondence exchanged between myself and Mr.
Halvorsen Hirschefield which have been marked as Exhibits “A” and “B” to the Complaint for Arrest
and Request for Security.
Sworn to under penalty of perjury, 28 U.S.C. § 1746 this 26th of December 2011.

12-26-2011________
Date

______/s/ Paxton N. Crew_______________
Paxton N. Crew