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used. Mahnich v. Southern S. S. Co. (1943), 321 U.S.

96, 103. See also, Vileski v. Pacific Atlantic S. S. Co.

(CCA 9, 1947), 163 F. (2d) 553; Page v. U. S. (CCA 9,

1949), 177 F. (2d) 601. This obligation v/as fully met

by Appellant.

As to the claimed negligence of Appellant, no au-

thority is given by Appellee in support of his theory.

In fact nowhere in Appellee's brief does he discuss

the cases in point which were cited in Appellant's Brief

(pp. 8, 9, 10), which cases stood for the proposition

(directly contrary to that urged by Appellee) that an

instrumentality properly used aboard a vessel for one

purpose cannot be changed into an unseaworthy ap-

purtenance nor render the owners negligent by reason

of being improperly used for another purpose by libel-



As supplemented by this Reply Brief, Appellant relies

upon its opening brief to answer Appellee's Brief and to

support its contention that the decree of the trial court

should be reversed.

Respectfully submitted,

Lofton L. Tatum,

John R. Brooke,

Wood, Matthiessen, Wood & Tatitm,

Proctors for Appellant.

archive.org Volume Name: govuscourtsca9briefs2992

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Document Link: http://archive.org/stream/govuscourtsca9briefs2992#page/n250/mode/1up

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