COUNCIL OF LEGAL EDUCATION

NORMAN MANLEY LAW SCHOOL

ADVOCACY PROGRAMME

YEAR II

CIVIL BRIEF

JENSEN (EXEC. ESTATE CARL JENSEN, dec”d) v. WHITE STAR

LINES LIMITED – (TITANIC II CASE)

NANCY ANDERSON

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 PARTICULARS OF CLAIM

IN THE SUPREME COURT OF JUDICATURE OF JAMAICA

CLAIM NO. HCV 2 of 2016

BETWEEN CHRISTINE JENSEN CLAIMANT

(EXECUTOR of the Estate
Of Carl Jensen, dec’d)

AND WHITE STAR LINES LIMITED DEFENDANT

1. The Claimant is the fiancé of the deceased and Executor of the Estate of Carl
Jensen, deceased, under his Will dated December 2, 2013 and for which Probate
was granted on February 14, 2015.

2. The Defendant is a limited liability company duly incorporated in Jamaica and the
owner and operator of a vessel named ‘Titanic II’ which sails between Bermuda
and the Bahamas.

3. On the 14th April, 2014 the Claimant and the deceased were passengers on the
Defendant’s vessel, Titanic II, sailing from Bermuda to Nassau in The Bahamas.
The deceased was therefore a lawful visitor to and the Defendant the occupier of
the premises within the meaning of the Occupiers Liability Act.

4. In the circumstances, the Defendant owed the deceased a common duty of care
under Section 3 of the Occupiers Liability Act, including a duty to provide a safe
trip to his destination, Nassau.

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5. The Defendant and its servants and/or agents, the crew of the Titanic II, behaved
in an unreasonable manner in breach of the Occupiers Liability Act and in acts of
negligence resulting in the ship sinking.

PARTICULARS OF BREACH OF STATUTORY DUTY/NEGLIGENCE

The Defendant, its servants and/or agents were in breach of their statutory
duty and/or negligent in:-
(a) Failing to reduce speed, after the first metallic bang;
(b) Failing to properly investigate the noise emanating from the
bow;
(c) Delaying in sounding the alarm;
(d) Failing to provide adequate guidance from the bridge;
(e) Placing the ship on autopilot, without a crew member
watching the ship;
(f) Providing a chaotic and disorganized evacuation process;
(g) Failing to have sufficient lifejackets on board.

6. By reason of the matters aforesaid the vessel The Titanic II sunk into the ocean
and the deceased drown in the sea on the 14th of April 2014.

7. At the time of his death the deceased was 21 years old, having been born on April
15, 1993. He was in good health. He was self employed as a computer
programmer and designer and earned approximately €2,000,000.00 per annum.

8. As a consequence of the aforesaid the deceased lost the normal expectation of life
and his estate has thereby suffered loss, damage and incurred expenses.

PARTICULARS OF SPECIAL DAMAGES

Funeral expenses - US $500,000.00

AND THE CLAIMANT CLAIMS

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 1. Damages under the Law Reform (Miscellaneous Provisions) Act for the
benefit of the estate of the deceased.
2. Interest on such damages at such rates and for such persons as this
Honourable Court deems fit.
3. Costs

Signed: Jasmine Cart-Rite

Attorney-at-law

I certify that all the facts set out in this Particulars of Claim are true to the best of
my knowledge, information and belief.

Dated the 14th day of ay of January January___, 2016

Signed: Christine Jensen

The claimant’s address for service is that of his Attorneys-at-Law, Cart-Rite and
Pendin, whose telephone number is 145-0017 and fax number, is 145-0020.

Filed by Jasmine Cart-Rite, Attorney-at-law, Cart-Rite and Pendin, 12 Runaway Street,

Kingston whose telephone number is 145-0017 and fax number is 145-0018

WITNESS STATEMENT AND EXPERT REPORT

OF
PROFESSOR DAVID MOLYNEAUX

IN THE SUPREME COURT OF JUDICATURE OF JAMAICA

CLAIM NO. HCV 2 of 2016

BETWEEN CHRISTINE JENSEN CLAIMANT

(EXECUTOR of the Estate
Of Carl Jensen, dec’d)

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AND WHITE STAR LINES LIMITED DEFENDANT

I am David Molyneaux and I state as follows:

1. I am a professional engineer and ship safety expert; I have a B.Sc. from

Newcastle-Upon-Tyne, a M.Sc. from the University of British Columbia and a
PhD from Memorial University of Newfoundland and Laborador, Canada

2. I arrived at Memorial after a career in research and consulting in both public and
private sectors. I worked in St. John's from 1985 until 2008 carrying out research
into a range of topics related to marine safety, hydrodynamics and performance of
ships and offshore structures in ice. In 2008 I moved to Oceanic to manage the
development and acquisition of computer codes for predicting the performance of
ships and offshore structures in harsh environments. I joined the faculty of
Memorial University as a full Professor in January 2015.

3. In April 2014, I was commissioned by Hodge Insurance Company Limited a

Swedish Company to investigate and report on the sinking of the Titanic II in the
Atlantic Ocean between Bermuda and The Bahamas.

4. I interviewed several members of the crew of the Titanic, including the Captain
Amos Schettino, Second Officer Charles Herbert Lightoller and Chief Mate Earl
Thomas. I also interviewed passengers, including Christine Jensen, Michael Grant
and Maryann Lettman. I received information on the construction of the ship,
maintenance records and the ships log from White Star Lines Limited. Finally, I
received notes and reports submitted by various ship captains and helicopter pilots
who assisted in the rescue.

5. From these interviews, records and reports I have been able to generate this report
on what happened the night of April 14, 2014 and why the Titanic II sunk into the
Ocean.

6. The weather that night was rough, with a wind of 15-20 metres per second and a
significant wave height of 4-6 metres. Captain Schettino described the weather as
“normally bad”. The vessel was averaging a speed of 16-17 knots. This is
excessive, in my opinion the ship should have slowed down because of these
adverse conditions.

7. The first sign of trouble was when a metallic bang was heard by Crew Member
Thomas around 11:10 p.m. This was probably caused by a heavy wave hitting the
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 bow doors. Over the next 10 minutes similar noises were reported by all the
passengers I interviewed and by the crew members.

8. About 11:25 the ship took on a heavy starboard list, as water flooded unto the
vehicle deck. The ship slowed down and its six engines cut out completely.

9. The ship sank about 11:45 p.m. because nine of the ship’s eleven watertight
compartment doors were torn open and the water spread.

10. A ‘Mayday’ was communicated by the ship’s crew at 11:38. The crew’s actions
were critical: they failed to reduce the speed of the ship after the first metallic
bang, failed to properly investigate the noises and delayed in the sounding of an
alarm.

11. The ship had been put on autopilot and no crew member was on the bridge from
10:30 p.m. This accounts for the failure to become aware of the danger to the ship
and its passengers.

12. Passengers reported a chaotic and disorganized evacuation process, with

contradictory orders given by various crew members. The listing caused serious
problems for the launching of the lifeboats and there were insufficient lifejackets
for crew and passengers.

13. I understand that it is my duty to help the Court impartially on all matters relevant
to my expertise and that duty overrides any obligation to Ms. Jensen or her
attorney who instructed me and who paid me for the report. I have read Part 32, in
particular Rules 32.3 and 32.4 of the Civil Procedure Rules and state that I believe
that I have carried out my duty in the manner set out in the Rules.

14. I have included all matters within my knowledge and area of expertise relevant to
the issue on which my expert evidence is given. There is nothing to my
knowledge which affects the validity of this report.

I certify that the matters contained in this Expert Report are true to the best of my
knowledge and belief and outlines all matters within my knowledge and area of expertise
relevant to the issue on which the expert evidence is given.

DATED THE 20th DAY OF March, 2016

_______David Molyneaux___

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Filed by Jasmine Cart-Rite, Attorney-at-law, Cart-Rite and Pendin, 12 Runaway Street,
Kingston whose telephone number is 145-0017 and fax number is 145-0014
DEFENCE

IN THE SUPREME COURT OF JUDICATURE OF JAMAICA

CLAIM NO. HCV 2 of 2016

BETWEEN CHRISTINE JENSEN CLAIMANT

(EXECUTOR of the Estate
Of Carl Jensen, dec’d)

AND WHITE STAR LINES LIMITED DEFENDANT

1. The Defendant puts the Claimant to proof of Paragraph 1 of the Particulars of

Claim.

2. Paragraphs 2, 3 and 4 of the Particulars of Claim are admitted.

3. The Defendant denies that the crew of the Titanic, its servants and/or agents,
behaved in breach of the Occupiers Liability Act or negligently and paragraph 5
of the Particulars of Claim and the Particulars set out thereunder are denied.

4. The Defendant says that the deceased was warned not to try to assist in the rescue
of other passengers and not to touch the lines used to lower lifeboats, but he failed
to follow these warnings and he appeared to be drunk.

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5. The Defendant says that the sinking of the Titanic II was an act of God, in that the
storm and bad weather was the sole proximate cause of the damage and injury
incurred, and not the negligence of the Defendant.

6. The Defendant further states that its crew members acted reasonably and in full
professional competence.

7. The Defendant admits that the deceased died as a result of the sinking of the ship
and admits paragraph 6 of the Particulars of Claim.

8. In response to paragraph 7 and 8 of the Particulars of Claim, the Defendant

requires the Claimant to prove the particulars alleged therein.

9. Further, the Defendant says that the deceased’s death was caused or contributed to
by his own negligence.

PARTICULARS OF NEGLIGENCE OF THE DECEASED

(a) Failing to heed the warnings of the risk by not getting into a lifeboat.
(b) Voluntarily assuming the risk of injury incidental to not listening to the
instructions of the ship crew;
(c) Voluntarily stepping out of a lifeboat when lowered although that lifeboat
was not full.
(d) Stepping-in to try to control fellow passengers, although told not to do so;
(e) Remaining on the ship in a drunken state.

10. In the circumstances, the Defendant also relies on the defence under section 3(7)
of the Occupiers Liability Act and/or volenti non fit injuria in that the deceased
with full knowledge of the risks; he did nevertheless voluntarily assume that risk.

11. Further and in the alternative the Defendant says that it, its servants and/or agents
took all reasonable precautions and undertook adequate measures prevent the ship
from sinking and to rescue passengers, including the deceased. .
PARTICULARS

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 a) Slowing the ship down to prevent further leaks and further water from
entering the bow;
b) Sounding the alarm in a timely manner;
c) Providing ample and able assistance to passengers to enter lifeboats and be
rescued;

12. In all the circumstances the Defendant denies breach of statutory duty and/or
negligence on the part of its servants and/or agents.

13. The Defendant denies that the Claimant is entitled to the damages claimed or any
damages at all.

Dated the 1st day of March 2016

Signed: William Dayz, ______
Attorney-at-law

I certify that all the facts set out in this Defence are true to the best of my knowledge,
information and belief.

Signed: John Wilde

CEO –White Star Lines Limited

The defendant’s address for service is that of his Attorneys-at-Law, Dayz, & Goodrich of
10 Star Road, Kingston 5 whose telephone number is 145-0017 and fax number is 145-
0020.

Filed by Dayz and Goodrich, Attorneys-at-Law of 10 Star Road, Kingston 5 whose

telephone number is 145-0017 and fax number is 145-0020.

WITNESS STATEMENT OF CHRISTINE JENSEN

IN THE SUPREME COURT OF JUDICATURE OF JAMAICA

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CLAIM NO. HCV 2 of 2016

BETWEEN CHRISTINE JENSEN CLAIMANT

(EXECUTOR of the Estate
Of Carl Jensen, dec’d)

AND WHITE STAR LINES LIMITED DEFENDANT

1. My name is Christine Jensen and I live in Oslo, Sweden. I was the fiancé of Carl
Jensen, a computer programmer from Oslo, Sweden.

2. In December 2013, Carl and I agreed to marry in May 2014 and we both wrote
wills in which we were named as each other’s sole executor and beneficiary.

3. We decided it would be romantic to get married in Nassau in The Bahamas and

we decided to fly from Sweden to Bermuda and take the inaugural voyage of the
Titanic II from Bermuda to The Bahamas in April 2014.

4. We chose the Titanic II as our means of travel because it was supposed to be

“unsinkable” and “the safest boat in the world”. We were very excited about
being on such a new boat.

5. I stayed, on the ship, in a cabin on Deck F, in the back part of the boat with other
single women, and Carl and his two friends Niels and Hans stayed on the other
end of the boat.

6. Around ten o’clock in the evening of April 14, 2014, I remember being awoken
by a loud sound. I did not think much of it at the time and tried to go back to
sleep. The, about 10 minutes later the girls in the next cabin came and woke me
up, saying we had to leave the ship immediately as something was wrong.

7. We rushed up the stairs to the lifeboat deck. As I got to the top I saw Carl. He was
helping to load passengers on the lifeboats. He was not the only passenger
helping, there were others because there did not seem to be enough crew members
to load all the passengers.

8. Carl headed me towards the railing to get on a lifeboat. I could see that only
women, children and crew members were being loaded on the lifeboats. Everyone
seemed concerned but no one was screaming. I could even hear the band playing:
Nearer My God to Thee!”.

9. When it was my turn to get on the boat, Carl told me I would probably reach
Nassau before him and I should look out for him there. He gave me a hug and a
kiss and said he would see me soon. After I sat down in the boat, I saw Carl help a

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 crew member get the ropes that lowered the lifeboat unstuck and he stood at the
rail while the boat moved away from the ship. This was about 11:35 p.m. that
night and was the last time I saw Carl.

10. I have known Carl for over 20 years; we grew up in the same hometown, attended
the same schools and played together often. He learned computer programming at
Cooper’s Tech. School and was a freelance designer, earning in excess of 5,
000,000.00 per annum.

11. I have been to several of his birthday parties since boyhood and know that he was
born on April 15th and was nearly 21 years of age on April 14, 2014. Both Carl
and I wrote wills in December 2013 and named each other as Executors. I am the
sole Executor of Carl’s will and have applied for probate in Jamaica and it was
granted to me on February 14, 2015.

I believe that the facts stated in this witness statement are true.

Signed ___Christine Jensen____

Dated the 24th day of April 2016

Filed by Jasmine Cart-Rite, Attorney-at-law, Cart-Rite and Pendin, 12 Runaway Street,

Kingston whose telephone number is 145-0017 and fax number is 145-0016
WITNESS STATEMENT OF MICHAEL ST. AUBRYN GRANT

IN THE SUPREME COURT OF JUDICATURE OF JAMAICA

CLAIM NO. HCV 2 of 2016

BETWEEN CHRISTINE JENSEN CLAIMANT

(EXECUTOR of the Estate
Of Carl Jensen, dec’d)

AND WHITE STAR LINES LIMITED DEFENDANT

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 1. My name is Michael St. Aubryn Grant and I live at 16 Oxford Road, Kingston 5
in the Parish of St. Andrew and I am a salesman for Courts in Kingston.

2. In April 2014 I took a holiday and flew to Bermuda to visit my girlfriend, Myrtle
Tomlinson, who lives and works there as the Manager of Courts store in
Hamilton, Bermuda.

3. I spent one week with her and was aboard the Titanic II going to Nassau to catch
a flight back to Jamaica.

4. On April 14, 2014 I retired after dinner to my cabin and was asleep when about
11:15 p.m. I was awakened by a loud metallic banging noise; it was more than
one bang. I also felt the ship as though it was tilting. I became frightened and
quick got dressed and climbed upon the deck of the ship.

5. By the time I got to the deck I saw crew members lowering lifeboats and shouting
“women and Children, only”. Everything was very chaotic, people running every
which way, ropes around lifeboats tied up and people trying to get into lifejackets.

6. I tried to get a lifejacket from one of the crew members but he said they were for
women and children only, although he already had one on. He also told me I
could not get on a lifeboat though I could see some of them being set down in the
sea with spaces available.

7. A few minutes later, a passenger I had met the day before, Carl Jensen, handed
me a lifejacket and also helped me into a lifeboat which he assisted to lower into
the sea. It was about 11:40 p.m. and within a few minutes the ship sank into the
sea.

8. Thanks to Mr. Jensen’s help, I was safe in the lifeboat and rescued an hour or so
later by a US Coast Guard vessel.

I believe that the facts stated in this witness statement are true.

Signed ___Michael St. A. Grant____

Dated the 24th day of July 2016

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Filed by Jasmine Cart-Rite, Attorney-at-law, Cart-Rite and Pendin, 12 Runaway Street,
Kingston whose telephone number is 145-0017 and fax number is 145-001
WITNESS STATEMENT OF SECOND OFFICER CHARLES HERBERT
LIGHTOLLER for the Defendant

IN THE SUPREME COURT OF JUDICATURE OF JAMAICA

CLAIM NO. HCV 2 of 2016

BETWEEN CHRISTINE JENSEN CLAIMANT

(EXECUTOR of the Estate
Of Carl Jensen, dec’d)

AND WHITE STAR LINES LIMITED DEFENDANT

I am Second Officer Charles Herbert Lightoller, of Hamilton, Bermuda and employed to

White Star Lines Limited.

1. In April 2014 I was assigned as Second Officer to Captain Amos Schettino on the
maiden voyage of the Titanic II from Bermuda to Nassau in the Bahamas.
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2. The ship had an uneventful voyage up until the night of April 14th. I came on duty
that night at 6:00 p.m. for my watch, which ends at 10:00 p.m. Around 7:30 p.m.
when I finished my dinner, I noticed that the wind had increased since I began my
watch and was now 15-20 metres per second and there was a significant wave
hitting the ship. This is not bad weather, but also not normal weather.

3. Captain Schettino came on the bridge about 9:00 p.m. and he and I discussed the
situation and neither he nor I were alarmed about the wind or waves. The Captain
left the bridge about 9:20 p.m. saying he was going to his cabin for the night.

4. At 10:00 p.m. my shift was over so I gave First Officer Murdoch the ship’s course
and speed and I went to my bed. Murdoch drown at the time of the sinking of the
ship. I found out later that he had put the ship on autopilot and that no crew
member was on the bridge from 10:30 p.m. that night.

5. Around 11:10 p.m. as I was just closing my eyes, I felt a vibration and heard a
loud metallic bang. In the next 10 minutes I heard similar banging noises. I got
out of bed around 11:25 p.m. and headed towards the bridge. I felt the ship take
on a heavy starboard list and slow down.

6. The internal alarm was sounded as I reached the bridge about 11:30 p.m. this is
also called the lifeboat alarm, warning passengers that they should take a
lifejacket and board a lifeboat. There were enough lifejackets for all passengers
and the crew as well as enough lifeboats.

7. The listing caused problems in that passengers had difficulties reaching life boats
and the launching of some lifeboats was hampered by the listing and the
entanglement of ropes. I remember seeing a passenger trying to assist the crew
untangling lines on the lifeboats. I called over to him and said it was not necessary
that he help us. He responded that Officer Moody asked him to work on these
lines while Moody worked on the lines on the other end of the lifeboat.

8. Officer Moody, I am sad to say, did not survive the sinking of the ship.

9. When we had finished loading this particular lifeboat, the said passenger jumped
down and asked me if I had seen his fiancée Christine Jensen. I smelled alcohol
on his breath and asked him if he had been drinking and he said he had had only a
two drinks with friends. I asked what class his finance was in and directed him to
where she would most likely be getting into a lifeboat. I saw him run to that life

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 boat and saw him kiss a young lady, who I presumed was his fiancé and help her
into a lifeboat

10. About this time the ship was sinking very fast and I saw Lieutenant Mauritz
Steffanson a Swedish military attaché trying to help control the crowd which were
now very frightened. Steffanson got into one of the last lifeboats lowered. I saw
the passenger with the fiancé return again wanting to assist and again I told him
we didn’t need his help, but he did seem to be doing a good job. I told him to get
in the last lifeboat with Steffanson and he did.

11. Just after this passenger, who I now realize was Carl Jensen, got into the boat,
more women showed up, so I told everyone in the boat to make room. Jensen and
some of the men in the boat jumped out and allowed the women in and we
lowered the boat. to the sea. When I turned around, I did not see Jensen anywhere.
I never saw him again.

12. The water was now rising so rapidly I jumped onto the roof of the officers’
quarters. The deck was now tilting so steeply that I fell into the water. One of the
boat’s funnels started to fall towards me and I tried to get away from it and ended
up near a grate over an engine room air intake. The force of the water filling the
air intake sucked me down against the grate as the boat went under. Luckily the
water rushing through the grate hit the boilers, which blew and blasted me back to
the surface. I swam to a lifeboat which was upside down and pulled myself on top
of it with other crew members and we remained there until a Coast Guard boat
arrived and took us aboard in the morning. I believe I was the last man pulled
from the water alive.

I believe that the facts stated in this witness statement are true.

Signed __ Charles Herbert Lightoller ____

Dated the 28th day of July 2016

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Filed by Dayz and Goodrich, Attorneys-at-Law of 10 Star Road, Kingston 5 whose
telephone number is 145-0017 and fax number is 145-0020

WITNESS STATEMENT OF LIEUTENANT MAURITZ STEFFANSON

For the Defendant

IN THE SUPREME COURT OF JUDICATURE OF JAMAICA

CLAIM NO. HCV 2 of 2016

BETWEEN CHRISTINE JENSEN CLAIMANT

(EXECUTOR of the Estate
Of Carl Jensen, dec’d)

AND WHITE STAR LINES LIMITED DEFENDANT

1. I am Lieutenant Mauritz Steffanson, of Stockholm, Sweden and I am the Military

Attaché to the Consulate of the Government of Sweden in New York City.

2. I was traveling on vacation leave on the inaugural voyage of the Titanic II from
Bermuda to The Bahamas in April 2014. I was traveling alone.

3. On the evening of April 14, 2014 I was drinking lemonade in the first class
smoking room with several other gentlemen. At 11:10 p.m. we all heard a very
loud metallic bang. The bang however did not interrupt my vigorous debate with
Hugh Woolner about the changing world order. Our debate was interrupted a few
minutes later by a White Star Line officer who told me that I needed to put on my
lifejacket immediately. Since I am a military man, I obeyed the officer, put on my
lifejacket and went to see how I could help the other passengers.

4. As I approached the deck I saw that it was busy with passengers from all classes. I
immediately stood to and assisted women and children to board the lifeboats.
Hugh reassured the women as they were waiting to board. He joined me as I
helped passengers such as Mrs. Edward Candee, into the boats.

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5. I had been working on untangling the ropes to one of the lifeboats, which
presented some difficulty due to their poor design, when this man, who I later
learned was Carl Jensen, rudely pushed me out of the way. He jumped up on the
rail and rashly untangled the ropes while hanging over open water.

6. Officer Lightoller came over and told Jensen to get down from the railing. When
he jumped down next to me, to where I stood waiting to explain to him how a
gentleman behaves, I was not surprised to smell alcohol on his breath, which no
doubt gave him the courage to do such a foolish thing. Officer Lightoller must
have smelled the alcohol also because he asked Jensen if he had been drinking
before I had a chance to say anything.

7. While Officer Lightoller was reprimanding Jensen, I went over to comfort the
distraught ladies. As I continued to comfort ladies, I saw over their shoulders
Jensen kissing some woman who may have been his purported fiancé.

8. As we were accompanying the ladies towards the remaining lifeboats I heard a

shot and saw that Officer Lightoller had his men in a ring around one of the
lifeboats and some of them had their guns at the ready. Jensen was once again
interfering the officers by standing before them; blocking their line of fire should
the crowd become uncontrollable.

9. Seeing how unruly the crowd had become, I told the passengers, a few of whom
were even first class passengers, to back away and let the sailors do their job. I
kept looking over my shoulder to make sure the sailors were assembling the boat
properly. Jensen continued to interfere with the officers doing their job properly,
but did keep the crowd far away from the officers so that they could readily use
their sidearms where was a need to do so.

10. Once all the women in the immediate area had been loaded, Lightoller allowed
certain men to board. Jensen quickly got on board. I hung back in case there were
other women who needed to board, which as it turned out there were. When
Lightoller called for the passengers in the boat to make room, Jensen to my
surprise, got out of the lifeboat rather than simply moving over like some other
passengers.

11. Once these women were boarded, unfortunately, Lightoller appeared to have lost
his nerve and ordered the boat lowered, when I could clearly see there were empty
seats in the boat. Jensen had calmed down the other men so there was nothing else
for Hugh and I to do. This was the last I saw of Jensen.

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 12. I called to Hugh and we both jumped into the lifeboat being lowered. I let Hugh
jump first. With a short jump, I dropped a surprising distance into that part of the
boat where there were no ladies. Our landing in the boat caused no serious
disruption and we continued to assist in calming the ladies.

13. We were rescued by morning’s first light by a very hospitable crew on board a US
military cruiser. I only suffered a few bruises from my jump and landing in the
lifeboat, but Hugh did not complain of any injury. It was a very frightful sight
however, watching the Titanic II sink in the waters.

I believe that the facts stated in this witness statement are true.

Signed __ Lieutenant Mauritz Steffanson ____

Dated the 28th day of July 2016

Filed by Dayz and Goodrich, Attorneys-at-Law of 10 Star Road, Kingston 5 whose

telephone number is 145-0017 and fax number is 145-0020.

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