Recent Firm News

Palmer Biezup & Henderson is dedicated to obtaining favorable outcomes for our clients. In addition to their work in the courtroom and conference room, our attorneys are active in their profession and their communities.

June 2, 2014

Court sustains Rule B attachment of “debts” owed by a U.S. subsidiary to a foreign parent and orders the subsidiary to deposit funds to secure the plaintiff’s claim with the court.

Palmer attorneys represented the plaintiff Cargo-Levant Schiffarhrtsgesellschaft MbH, which held an arbitration award against an Indian company, PSL Limited, following the London arbitration of a charter party dispute. Research revealed that two wholly-owned subsidiaries of PSL Limited were incorporated in Delaware and that certain debts were owed by the subsidiaries to the parent. A complaint seeking attachment of intangible debts owed by the subsidiaries as garnishees pursuant to Admiralty Rule B was filed in the Delaware federal district court and the court issued writs of attachment against the subsidiaries. The subsidiary garnishees contested the validity of the attachment on various grounds, including an argument that the debts were contingent and not subject to attachment because the parent had agreed that no repayment was required. In a thorough opinion the District Court confirmed the validity of the Rule B attachment and ordered the garnishees to deposit $800,000 in the registry to secure the plaintiff’s claim. The decision is notable inasmuch as there are only a few reported decisions addressing the attachment of debts and other intangible property under Rule B. For additional information contact Frank P. DeGiulio or Kevin O’Donovan. For a copy of the Cargo Levant Memorandum Order, click here (1.4 mb PDF).

June 2, 2014

The Maritime Law Association of the United States will hold its semi-annual meetings in Philadelphia from October 22nd to 24th, 2014. Frank P. DeGiulio is chairing the meeting arrangements committee and other Palmer attorneys are serving on various subcommittees.


Palmer attorneys have authored a number of significant articles exploring nuances of legal theory and practice and examining case law. A list of maritime law publications follows; please contact the firm to obtain full-text copy.

Boating Briefs

Boating Briefs is a publication of the Recreational Boating Committee of The Maritime Law Association of the United States. Michael B. McCauley and Frank DeGiulio have each served as chairs of the committee. For more than ten years, attorneys from Palmer Biezup &Henderson LLP have edited Boating Briefs; the current editor is Daniel Wooster. Please browse or search the current and past issues through this link below to review significant decisions in this specialized area of maritime law.