IN THE UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

IN ADMIRALTY 

CASE NO.: 0:20-cv-60970-RS

IN RE THE COMPLAINT OF:

LOHENGRIN, LTD., as owner of the 2006 

M/Y Lohengrin, a 2006, 161-foot aluminum 

trideck motoryacht from Trinity Yachts,

IMO Number 8735998, for Exoneration from or 

Limitation of Liability

_______________________________________ /

RESPONDENT, TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA AS

SUBROGEE OF (A/S/O) TIN MAN’S PRIDE. LLC, ANSWER AND AFFIRMATIVE

DEFENSES AND CLAIM TO PETITIONER’S VERIFIED COMPLAINT FOR

EXONERATION FROM OR LIMITATION OF LIABILITY

COMES NOW, Respondent/Claimant, TRAVELERS PROPERTY CASUALTY

COMPANY OF AMERICA AS SUBROGEE OF (A/S/O) TIN MAN’S PRIDE, LLC

("TRAVELERS”), a foreign corporation, files this its Answer, Affirmative Defenses, and

Claim in response to Petitioner’s LOHENGRIN, LTD., as owner of the 2006 M/Y

Lohengrin, a 2006, 161-foot aluminum trideck motoryacht from Trinity Yachts, IMO

Number 8735998, Verified Complaint for Exoneration From or Limitation of Liability, and

states as follows:

1. Admitted that this action was brought pursuant to this Court’s admiralty 

jurisdiction. Denied that Petitioner is entitled to exoneration or limitation of liability.

2. Admitted.

3. Admitted only that Petitioner is the owner of the yacht M/Y Lohengrin, IMO 

Number 8735998, and that it is currently located in Ft. Lauderdale, Florida. Any and all 

other allegations not specifically admitted are denied.

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4. Admitted only that on November 16, 2019, the M/Y Lohengrin was docked 

at Universal Marine Center, that it caught fire and subsequently caused damages to the 

M/Y Tin Man’s Pride. Any and all other allegations not specifically admitted are denied.

5. Admitted only that venue in this District Court is proper under Rule F(9) of 

the Supplemental Admiralty and Maritime Claim Rules. Denied that Petitioner is entitled 

to exoneration or limitation of liability. Respondent/Claimant is without sufficient 

knowledge or information in which to respond to the remaining allegations of paragraph 

5, and thus, they are denied.

6. Admitted only that Petitioner is owner of the yacht M/Y Lohengrin, IMO

Number 8735998. Any and all other allegations not specifically admitted are denied.

7. Denied.

8. Denied.

9. Denied.

10. Denied.

11. Admitted only that Respondent/Claimant has made/brought a claim against 

Petitioner. Respondent/Claimant is without sufficient knowledge or information in which 

to respond to the remaining allegations of paragraph 11, and thus, they are denied.

12. Denied. Respondent/Claimant reserves its right to contest the value of the 

M/Y Lohengrin.

13. Denied.

14. Admitted.

15. Admitted only that Petitioner is owner of the yacht M/Y Lohengrin, IMO

Number 8735998. Any and all other allegations not specifically admitted are denied.

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16. Denied as phrased.

Any and all allegations contained in the Complaint, including the WHEREFORE 

clause, that are not specifically admitted herein are hereby denied.

WHEREFORE, Respondent/Claimant, TRAVELERS PROPERTY CASUALTY 

COMPANY OF AMERICA AS SUBROGEE OF (A/S/O) TIN MAN’S PRIDE, LLC, 

requests that Petitioner’s, LOHENGRIN, LTD., as owner of the 2006 M/Y Lohengrin, a 

2006, 161-foot aluminum trideck motoryacht from Trinity Yachts, IMO Number 8735998, 

Verified Complaint for Exoneration From or Limitation of Liability, be dismissed and that 

Respondent/Claimant recover its costs.

AFFIRMATIVE DEFENSES

FIRST AFFIRMATIVE DEFENSE

The incident occurring on or about November 16, 2019, as described in the 

Complaint was proximately caused, in whole or in part, or was contributed to, in whole or 

in part, by the negligence, fault and/or want of care of Petitioner, LOHENGRIN, LTD., 

and/or its agents, managers, officers, directors, servants, crew and/or employees. 

Accordingly, the Limitation of Liability Act does not apply to this case.

SECOND AFFIRMATIVE DEFENSE

The incident occurring on or about November 16, 2019, as described in the 

Complaint was caused by the unseaworthiness of the M/Y Lohengrin, a 2006, 161-foot 

aluminum trideck motoryacht from Trinity Yachts, IMO Number 8735998. Accordingly, the 

Limitation of Liability Act does not apply to this case.

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THIRD AFFIRMATIVE DEFENSE

At all material times, the unseaworthiness of the M/Y Lohengrin, a 2006, 161-foot 

aluminum trideck motoryacht from Trinity Yachts, IMO Number 8735998, and/or the 

negligence, fault and/or want of care of the Petitioner, LOHENGRIN, LTD., and/or its 

agents, managers, officers, directors, servants, crew and/or employees and/or were 

within Petitioner’s privity and/or knowledge. Accordingly, the Limitation of Liability Act 

does not apply to this case.

FOURTH AFFIRMATIVE DEFENSE

The incident occurring on or about November 16, 2019, as described in the 

Complaint causing Respondent’s/Claimant’s damages was not the result of any 

negligence or fault of Respondent/Claimant or of those for whom they were responsible.

FIFTH AFFIRMATIVE DEFENSE

The limitation fund is inadequate. Pursuant to Supplemental Rule F (1), Petitioner 

failed to satisfy the limitation fund by depositing the appropriate security for the value of 

the M/Y Lohengrin, a 2006, 161-foot aluminum trideck motoryacht from Trinity Yachts, 

IMO Number 8735998.

SIXTH AFFIRMATIVE DEFENSE

Pursuant to Supplemental Rule F (7), the limitation fund is inadequate and must 

be increased.

SEVENTH AFFIRMATIVE DEFENSE

To the extent that this Honorable Court determines that the Limitation of Liability 

Act applies to this case, the limitation fund should include any and all proceeds from any 

judgment, award or settlement which may be received by Petitioner from any third party

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in recompense of any losses or damages sustained herein to the property or interests of 

Petitioner as a result of the fault or alleged fault of said party.

EIGHTH AFFIRMATIVE DEFENSE

Respondent/Claimant reserves the right to contest the appraisal value of the M/Y

Lohengrin, a 2006, 161-foot aluminum trideck motoryacht from Trinity Yachts, IMO 

Number 8735998, including, but not limited to, the value of its appurtenances, engines, 

apparel, pending freight, and any additional vessels in the flotilla, and the adequacy of 

the security thereof.

NINTH AFFIRMATIVE DEFENSE

Pursuant to the "Savings to Suitors” clause, 28 U.S.C. §1333, and all state law 

remedies, Respondent/Claimant, in filing this Answer and Claim, reserves all rights to 

pursue any and all available claims in the forum of its choosing, including state court, for 

resolution of any and all issues beyond the exclusive jurisdiction of this Admiralty Court, 

and to have such claims and related damages tried to a jury. The filing of this Answer and 

Claim in no way constitutes a waiver of these rights and defenses, and 

Respondent/Claimant does not, through this filing, agree to join all issues in this 

proceeding.

TENTH AFFIRMATIVE DEFENSE

Pursuant to the "Savings to Suitors” clause, 28 U.S.C. §1333, and all state law 

remedies, Respondent/Claimant, in filing this Answer and Claim, reserve the right to move 

for bifurcation of this action so as to enable Respondent/Claimant to select a court and/or 

forum of its choosing for all fact issues other than the issues related to Petitioner’s claim 

to limit liability.

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ELEVENTH AFFIRMATIVE DEFENSE

The Limitation of Liability Act does not apply to this case, because, at all relevant 

times, the M/Y Lohengrin, IMO Number 8735998, was operated in a willful, wanton and 

reckless manner, or alternatively, the condition and actions resulting in 

Respondent’s/Claimant’s damages took place with the privity and knowledge of 

Petitioner.

TWELFTH AFFIRMATIVE DEFENSE

Respondent/Claimant reserves the right to seek amendment of additional

affirmative defenses that may become known during the course of this action.

AND NOW, specifically reserving all defenses asserted herein,

Respondent/Claimant, TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA

AS SUBROGEE OF (A/S/O) TIN MAN’S PRIDE, LLC, files its Claim in the Verified

Complaint for Exoneration From or Limitation of Liability, and states that:

CLAIM OF TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA

AS SUBROGEE OF (A/S/O) TIN MAN’S PRIDE, LLC

A. Nature of the Claim

1. Respondent/Claimant, TRAVELERS PROPERTY CASUALTY COMPANY 

OF AMERICA AS SUBROGEE OF (A/S/O) TIN MAN’S PRIDE, LLC ("TRAVELERS”), reasserts each and every defense and objection set forth above as if stated verbatim herein.

2. This is a claim for negligence and vicarious liability under the General 

Maritime Law of the United States and the laws of the State of Florida.

B. Facts Specific to the Claim

3. At all times material, LOHENGRIN, LTD., is a foreign corporation organized 

and existing under the laws of the Republic of the Marshall Islands.

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4. At all times material, LOHENGRIN, LTD., owned, operated, maintained 

and/or controlled the M/Y Lohengrin, a 2006, 161-foot aluminum trideck motoryacht from 

Trinity Yachts, IMO Number 8735998 ("M/Y Lohengrin”), and/or the crews, persons 

and/or entities working aboard the M/Y Lohengrin were agents, servants and/or 

employees of LOHENGRIN, LTD., and subject to its control so that LOHENGRIN, LTD., 

is vicariously liable for their acts or omissions.

5. At all times material, the M/Y Lohengrin was on navigable waters of the 

United States.

6. At all times material, the M/Y Lohengrin was a vessel with numerous defects 

that rendered it unseaworthy for its intended purpose.

7. At all times material, Tin Man’s Pride, LLC, owned the M/Y Tin Man’s Pride, 

a 2010 Malle yacht.

8. At all material times, the M/Y Lohengrin was docked at Universal Marine 

Center located in Ft. Lauderdale, FL.

9. At all material times, the M/Y Lohengrin was undergoing extensive repairs 

and renovations. These repairs included painting and refinishing work, which included the 

use of oil-based paints and stains.

10. At all material times, the M/Y Tin Man’s Pride, was also docked at Universal 

Marine Center in a boat slip near the M/Y Lohengrin.

11. During the early morning hours of November 16, 2019, the M/Y Lohengrin 

caught fire.

12. As a result of the fire, the M/Y Tin Man’s Pride sustained significant damage.

13. At all times material hereto, TRAVELERS was a foreign corporation

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authorized to conduct business within the State of Florida, which conducted business 

within Broward County, Florida, including, but not limited to, writing and issuing insurance 

policies.

14. At all times material, TIN MAN’S PRIDE, LLC, had in effect a policy of 

insurance with TRAVELERS insuring the 2010 Malle yacht, M/Y Tin Man’s Pride, under 

policy number ZYM-51M09676-19-ND. A copy of the insurance policy is attached as 

Exhibit "A” and made a part hereof.

15. At all times material hereto, and within the policy period, as a result of the 

damage sustained by Tin Man’s Pride, LLC, and pursuant to its contract of insurance, 

TRAVELERS paid Tin Man’s Pride, LLC, the total sum of Eighty-Seven Thousand and 

One Hundred Fifty-One Dollars and Sixty-Two Cents ($87,151.62).

16. Accordingly, TRAVELERS is subrogated to any right of action the Tin Man’s 

Pride, LLC, may have had against the entity, here LOHENGRIN, LTD., which caused the 

insured injury. See State Farm Mutual Auto. Ins. Co. v. Hassen, 650 So. 2d 128, 132 

(Fla. 2d DCA 1995).

17. Respondent/Claimant has been damaged in a sum in excess of the 

minimum jurisdictional limits of this Honorable Court. See 28 U.S.C. § 1332.

18. At all times material, Respondent’s/Claimant’s damages were not the result 

of any negligence or fault of Respondent/Claimant and/or for those to whom it was 

responsible.

19. At all times material, all conditions precedent to the institution of this action 

have been performed, occurred, waived or otherwise have been excused.

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COUNT I

NEGLIGENCE OF LOHENGRIN, LTD.

20. Claimant reasserts, re-alleges and incorporates by reference paragraphs 1 - 

19 above as if fully stated herein and further allege:

21. LOHENGRIN, LTD., (including its managers, officers and directors which 

were involved with its repair and renovation (hereinafter "LOHENGRIN”)) owed to 

Claimant the duty to exercise reasonable care consistent with prudent seamanship in 

renovating and repairing the M/Y Lohengrin to ensure that it did not catch on fire and 

damage other boats, including the M/Y Tin Man’s Pride, and property.

22. This includes a duty of reasonable care in the operation and maintenance 

of the M/Y Lohengrin during renovations and repair.

23. LOHENGRIN breached these duties, and thus, was negligent, negligent per 

se, and/or grossly negligent in a number of different ways including but not limited to:

a. negligently failing to have adequate safety equipment, safety 

procedures/protocols and/or personnel/crew in place to prevent a fire and/or to extinguish 

a fire during repair and/or renovations of the M/Y Lohengrin, including but not limited to, 

(i) the proper storage of painting equipment/machinery; (ii) the disposal of soiled paint 

and varnishing rags; and (iii) maintaining the proper ventilation/ air conditioning on the 

M/Y Lohengrin to avoid fire hazards;

b. negligently failing to follow industry standards when painting and/or 

varnishing the interior of the M/Y Lohengrin to prevent it from catching fire during repair 

and/or renovations;

c. negligently selecting and/or retaining persons, contractors, subcontractors 

and/or entities, including but not limited to, Atlantic Refinishing Crew, Inc., Dutch

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Superyacht Painters, B, New Image Yacht Refinishing, and/or other entities to be 

determined, to perform repair and /or renovation work on the M/Y Lohengrin.

d. negligently supervising, instructing and/or training its employees, crew, 

contractors, subcontractors, and/or the entities hired to perform renovation and/or repair 

work, including but not limited to, Atlantic Refinishing Crew, Inc., Dutch Superyacht 

Painters, B, New Image Yacht Refinishing, and/or other entities to be determined, in 

relation to: (i) the proper storage of painting equipment/machinery; (ii) the disposal of 

soiled paint and varnishing rags; and (iii) maintaining proper ventilation/ air conditioning 

on the M/Y Lohengrin to avoid fire hazards;

e. negligently failing to maintain proper ventilation/ air conditioning on the M/Y

Lohengrin while it was undergoing to repair and renovation to avoid fire hazards;

f. negligently instructing and/or allowing its employees, crew, contractors, 

subcontractors, Atlantic Refinishing Crew, Inc., Dutch Superyacht Painters, B, New Image 

Yacht Refinishing, and/or other entities to be determined, to perform renovation and/or 

repair work in an unsafe manner;

g. negligently failing to inspect or maintain the M/Y Lohengrin at the 

completion of the work day to confirm that painting equipment/machinery and soiled paint 

and varnishing rags were not left onboard the M/Y Lohengrin;

h. negligently failing to exercise due care and caution when operating the M/Y

Lohengrin; and

i. any other violations of standard marine practice, regulations, industry 

standards, and/or acts of negligence by LOHENGRIN to be determined.

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24. These negligent acts by LOHENGRIN caused it to catch on fire which then 

caused substantial damage to the M/Y Tin Man’s Pride.

25. These negligent acts and deficiencies by LOHENGRIN which caused the 

M/Y Tin Man’s Pride to be damaged, were within the privity and knowledge of 

LOHENGRIN and/or LOHENGRIN knew or should have known of these negligent acts 

and deficiencies before this casualty occurred and failed to take proper precautions.

26. As a direct and proximate cause of LOHENGRIN’S breaches of its duties, 

Claimant, as subrogee of (a/s/o) Tin Man’s Pride, LLC, was damaged as more fully set 

forth above in the amount of Eighty-Seven Thousand and One Hundred Fifty-One Dollars 

and Sixty-Two Cents ($87,151.62).

COUNT II

VICARIOUS LIABILTY BY LOHENGRIN, LTD.

27. Claimant reasserts, re-alleges and incorporates by reference paragraphs 1 - 

19 above as if fully stated herein and further allege:

28. At all times material to this action, the LOHENGRIN, LTD., (including its 

managers, officers and directors which were involved with its repair and renovation 

(hereinafter "LOHENGRIN”)) was in the business of repairing and renovating yachts for 

resale.

29. At all times material hereto, LOHENGRIN owed and/or undertook a nondelegable duty that the repair and renovation work related to the M/Y Lohengrin would be 

performed in a reasonable, non-negligent and workmanlike manner.

30. At all times material hereto, the restoration work being performed on the 

vessel involved the use of chemical and other materials that rendered the work inherently 

dangerous. Specifically, the performance of the work, was such that in the ordinary

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course of events, performance of the work would probably cause injury if proper 

precautions were not taken.

31. Accordingly, LOHENGRIN was responsible for supervision, direction, 

management and control of all repair and restoration work on the M/Y Lohengrin, 

including, but not limited to, the work performed by its contractors and/or subcontractors, 

including but not limited to, Atlantic Refinishing Crew, Inc., Dutch Superyacht Painters, B, 

and/or New Image Yacht Refinishing. The Contracts are currently not in possession or 

control of the Plaintiff; however, upon receipt of the Contracts through discovery, they will 

be amended hereto.

32. Atlantic Refinishing Crew, Inc., Dutch Superyacht Painters, B, New Image 

Yacht Refinishing, and/or other entities yet to be determined were negligent in the 

following ways:

a. negligently failing to take appropriate safety precautions and/or have 

appropriate safety protocols and policies in place to prevent the M/Y Lohengrin from 

catching fire during repair and/or renovations;

b. negligently failing to follow industry standards when painting and/or 

varnishing the interior of the M/Y Lohengrin to prevent it from catching fire during repair 

and/or renovations;

c. negligently performing repair and /or renovation work on the M/Y Lohengrin;

d. negligently failing to inspect, dispose, and/or remove painting 

equipment/machinery and/or soiled paint and varnishing rags left onboard the M/Y

Lohengrin at the completion of the workday to avoid fire hazards;

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e. negligently failing to maintain proper ventilation/ air conditioning on the M/Y

Lohengrin while undergoing to repair and renovation to avoid fire hazards;

f. negligently supervising and/or training its employees and/or crew in relation 

to: (i) removing painting equipment/machinery, (ii) disposing of soiled paint and varnishing 

rags; and (iii) maintaining proper ventilation/ air conditioning on the M/Y Lohengrin while 

undergoing repairs and renovations to avoid fire hazards;

g. negligently instructing and/or allowing its employees and/or crew to perform 

repair and renovation work in an unsafe manner;

h. negligently failing to exercise due care and caution when performing 

renovation and repair work on the M/Y Lohengrin; and

i. any other violations of standard marine practice, regulations, industry 

standards, and/or acts of negligence to be determined.

33. The negligent acts of Atlantic Refinishing Crew, Inc., Dutch Superyacht 

Painters, B, New Image Yacht Refinishing, and/or entities yet to be determined caused 

the M/Y Lohengrin to catch fire which then caused substantial damage to the M/Y Tin 

Man’s Pride.

34. At all times material hereto, pursuant to Florida law, LOHENGRIN remained 

liable for Atlantic Refinishing Crew, Inc.’s, Dutch Superyacht Painters, B’s, New Image 

Yacht Refinishing’s, and/or yet to be determined entities’ negligence and negligent 

performance of the non-delegable duties undertaken by LOHENGRIN, including but not 

limited to, the negligence more fully described in paragraphs 32 and 33 above.

35. These negligent acts and deficiencies as more fully described in paragraphs 

32 and 33 above, which caused the M/Y Tin Man’s Pride to be damaged, were within the

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privity and knowledge of LOHENGRIN and/or LOHENGRIN knew or should have known 

of these negligent acts and deficiencies before this casualty occurred and failed to take 

proper precautions.

36. As a direct and proximate result of the negligence of Atlantic Refinishing 

Crew, Inc., Dutch Superyacht Painters, B, New Image Yacht Refinishing, and/or entities 

yet to be determined, for whom LOHENGRIN is vicariously liable, Claimant suffered 

damage as more fully set forth above in the amount of Eighty-Seven Thousand and One 

Hundred Fifty-One Dollars and Sixty-Two Cents ($87,151.62).

RESERVATION OF RIGHT TO JURY TRIAL

Claimant/Respondent reserves its right to a jury trial for all issues so triable.

PRAYER FOR RELIEF

WHEREFORE, Claimant, TRAVELERS PROPERTY CASUALTY COMPANY OF 

AMERICA AS SUBROGEE OF (A/S/O) TIN MAN’S PRIDE, LLC, prays that, after due 

proceedings, this Honorable Court:

a. Dismiss and/or Deny Petitioner’s, LOHENGRIN, LTD., Verified Complaint for

Exoneration from or Limitation of Liability and lift the injunction currently in place 

in this matter;

b. Require Petitioner to obtain an appropriate appraisal and deposit the security 

in the form of a cash deposit into the registry of the Court, so that the limitation 

fund reflects the full value of the M/Y Lohengrin, IMO Number 8735998, and 

any vessels in the flotilla which were under the common operation, control, and 

enterprise of Petitioner;

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c. Render judgment herein in favor of Claimant, and against Petitioner, for all 

damages as are warranted under general maritime law and/or Florida common 

law, pre-judgment interest accrued on such damage, and for all costs of these 

proceedings; and

d. Order all other relief to which Claimant is entitled to under law and equity.

Dated at Hollywood, Broward County, Florida, this 25th day of June, 2020.

KRAMER, GREEN, ZUCKERMAN, GREENE 

& BUCHSBAUM, P.A.

Attorneys for Travelers

4000 Hollywood Boulevard, Suite 485-South

Hollywood, FL 33021

Tel: (954) 966-2112

Fax: (954) 981-1605

By: /s/ Craig M. Greene________________

CRAIG M. GREENE, ESQ.

Fla. Bar No. 618421 

JEANETTE BELLON, ESQ.

Fla. Bar No. 45351

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 25th day of June, 2020, I electronically filed the 

foregoing with the Clerk of the Court by using the CM/ECF system. I also certify that the 

foregoing document is being served this day on all counsel of record on the attached 

Service List in the manner specified, either via transmission of Notices of Electronic Filing

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generated by CM/ECF or in some other authorized manner for those counsel or

parties who are not authorized to receive electronically Notices of Electronic Filing.

KRAMER, GREEN, ZUCKERMAN, 

GREENE & BUCHSBAUM, P.A.

Counsel for Travelers

4000 Hollywood Blvd., Suite 485-S

Hollywood, FL 33021

(954) 966-2112 - phone

(954) 981-1605 - fax

By: /s/ Craig M. Greene_________

CRAIG M. GREENE, ESQ.

Fla. Bar No. 618421

SERVICE LIST

CASE NO. 0:20-cv-60970-RS

Darren W. Friedman, Esq.

Jeffery Foreman, Esq.

Paul Bagely, Esq.

FOREMAN FRIEDMAN, P.A. 

One Biscayne Tower, Suite 2300 

2 South Biscayne Blvd.

Miami, FL 33131 

Tel: 305:358-6555 

Counsel for Petitioner

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