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The motion is followed by a Certificate of Service dated February 2, 2022.",{"@graph":14,"@context":73},[15,34,56],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/document/","Document",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/document/research-report/","Research & Report",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/document/motion-for-leave-to-amend-complaint-docket-no-22-01-february-2-2022/503051/",4,{"url":32,"name":10,"@type":35,"image":36,"author":41,"headline":10,"publisher":44,"fileFormat":47,"inLanguage":8,"description":12,"dateModified":48,"datePublished":49,"encodingFormat":47,"isAccessibleForFree":50,"interactionStatistic":51},"DigitalDocument",{"url":37,"@type":38,"width":39,"height":40},"https://docshare.wps.com/thumbnails/motion-for-leave-to-amend-complaint-docket-no-22-01-february-2-2022/503051.png","ImageObject",300,407,{"name":42,"@type":43},"Lucas Martin","Person",{"url":19,"name":45,"@type":46},"DocShare","Organization","application/pdf","2026-10-23","2026-10-03",true,{"@type":52,"interactionType":53,"userInteractionCount":55},"InteractionCounter",{"@type":54},"ViewAction",10,{"@type":57,"mainEntity":58},"FAQPage",[59,65,69],{"name":60,"@type":61,"acceptedAnswer":62},"What does CCMA request in the motion before the FMC?","Question",{"text":63,"@type":64},"CCMA requests leave to amend its Complaint in Docket No. 22-01.","Answer",{"name":66,"@type":61,"acceptedAnswer":67},"What changes does CCMA seek regarding the respondents?",{"text":68,"@type":64},"CCMA seeks to add Maersk A/S as a respondent and dismiss Safmarine Inc. as a respondent.",{"name":70,"@type":61,"acceptedAnswer":71},"When is the Certificate of Service dated?",{"text":72,"@type":64},"The Certificate of Service is dated February 2, 2022.","https://schema.org",{"og:url":32,"og:type":75,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":77,"canonical":32},"index,follow",{"doc_id":79,"site_id":7},503051,1791289934,{"code":4,"msg":82,"data":83},"success",[84,88,92,96,101,106,111,115,120,123,126],{"id":22,"doc_module":4,"doc_module_name":25,"category_name":85,"show_sort_weight":86,"slug":87},"Story & Novel",90,"story-novel",{"id":26,"doc_module":4,"doc_module_name":25,"category_name":89,"show_sort_weight":90,"slug":91},"Literature",80,"literature",{"id":33,"doc_module":4,"doc_module_name":25,"category_name":93,"show_sort_weight":94,"slug":95},"Exam",70,"exam",{"id":97,"doc_module":4,"doc_module_name":25,"category_name":98,"show_sort_weight":99,"slug":100},5,"Comic",60,"comic",{"id":102,"doc_module":4,"doc_module_name":25,"category_name":103,"show_sort_weight":104,"slug":105},6,"Technology",50,"technology",{"id":107,"doc_module":4,"doc_module_name":25,"category_name":108,"show_sort_weight":109,"slug":110},7,"Healthcare",40,"healthcare",{"id":112,"doc_module":4,"doc_module_name":25,"category_name":29,"show_sort_weight":113,"slug":114},8,30,"research-report",{"id":116,"doc_module":4,"doc_module_name":25,"category_name":117,"show_sort_weight":118,"slug":119},9,"Religion & Spirituality",20,"religion-spirituality",{"id":118,"doc_module":4,"doc_module_name":25,"category_name":121,"show_sort_weight":118,"slug":122},"World Cup","world-cup",{"id":55,"doc_module":4,"doc_module_name":25,"category_name":124,"show_sort_weight":55,"slug":125},"Lifestyle","lifestyle",{"id":127,"doc_module":4,"doc_module_name":25,"category_name":128,"show_sort_weight":97,"slug":129},19,"General","general",{"code":4,"msg":82,"data":131},{"doc_id":79,"user_id":132,"nickname":42,"user_avatar":133,"doc_module":4,"category_id":112,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":55,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":139,"language":140,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":12,"update_tm":144,"read_time":145},8796095360427,"https://ap-avatar.wpscdn.com/davatar_994ba38a5ba835b3df7d355c54d3ed8d","BEFORE THE  \nFEDERAL MARITIME COMMISSION  \nDOCKET NO. 22-01  \nCCMA, LLC  \nCOMPLAINANT,  \nv.  \nSAFMARINE INC. and PORTS AMERICA CHESAPEAKE, LLC  \nRESPONDENTS.  \nMOTION FOR LEAVE TO AMEND COMPLAINT  \nComplainant CCMA, LLC (“Complainant” or “CCMA”), by its undersigned attorneys, submits this Motion requesting leave for CCMA to amend its Complaint in the above-captioned matter, in accordance with Rules 66 and 69 of the FMC Rules of Practice and Procedure  \nOn January 27, 2022, Complainant filed a motion requesting a 25-day extension for Respondents to answer its Complaint. As indicated in its motion for extension, Complainant has learned additional information regarding the facts and circumstances surrounding the allegations in the Complaint and moves to amend its Complaint to add Maersk A/S as a Respondent in this action and dismiss Safmarine Inc. as a Respondent.  \nFor the foregoing reasons, Complainant respectfully requests that Your Honor grant this Motion to Amend Complaint.  \nRespectfully submitted,  \n___________________________  \nDavid K. Monroe  \nKristine O. Little  \nGKG LAW, P.C.  \n1055 Thomas Jefferson Street, NW Washington, DC 20007 Telephone: 202-342-5235  \nFacsimile: 202-342-5219  \n[dmonroe@gkglaw.com](dmonroe@gkglaw.com)  \n[klittle@gkglaw.com](klittle@gkglaw.com)[ ](klittle@gkglaw.com)Attorneys for CCMA, LLC  \nFebruary 2, 2022  \nCERTIFICATE OF SERVICE  \nI hereby certify that I have this 2nd day of February, 2022 served the foregoing document upon all parties of record by mailing a copy to each such person.  \nDavid K. Monroe  \nBEFORE THE  \nFEDERAL MARITIME COMMISSION  \nDOCKET NO.  \nCCMA, LLC.  \nCOMPLAINANT,  \nv.  \nMAERSK A/S and PORTS AMERICA CHESAPEAKE, LLC  \nRESPONDENTS.  \nCOMPLAINT  \nComplainant CCMA, LLC (“Complainant” or “CCMA”), by its undersigned attorneys, files this Complaint against Respondents herein, alleging violations ofthe Shipping Act of 1984, 46 U.S.C. § 40101, et. seq. (the “Shipping Act”) as follows:  \nI. COMPLAINANT  \n1. Complainant CCMA is a corporation organized and existing under the laws of the State of Delaware, with a principal place of business at 450 Corporate Parkway Suite 100 Amherst,  \nNY 14226.  \nII. RESPONDENTS  \n2. Maersk A/S is a Danish global ocean carrier company located at Esplanaden 50, DK-1098 Copenhagen, Denmark, with a United States office located at 180 Park Avenue, Building  \n105, PO Box 950, 07932 Florham Park, NJ. Maersk, by itself and through its common carrier subsidiaries and affiliated companies, provides container transportation and is the world’s largest  \ncontainer and supply vessel operator. Upon information and belief, at all relevant times, Maersk acted under its trade name Safmarine Inc. or through an agent under the name Safmarine Inc. Maersk is and was at all times pertinent to this Complaint a common carrier within the meaning of the Shipping Act, 46 U.S.C. § 40102(7), subject to regulation by the Federal Maritime Commission (“FMC”) .  \n3. Ports America Chesapeake, LLC (“PAC”) is a corporation organized and existing under the laws of the State of Delaware with a principal place of business at 1209 Orange Street Wilmington, DE 19801. PAC is and was at all times pertinent to this Complaint a marine terminal operator (“MTO”) within the meaning of the Shipping Act, 46 U.S.C. § 40102(15), subject to regulation by the FMC.  \nIII. JURISDICTION  \n4. The FMC has subject-matter jurisdiction over this Complaint pursuant to the Shipping Act of 1984, as amended.  \n5. This Complaint is being filed pursuant to Section 11(a) of the Shipping Act, 46  \nU.S.C. § 41301. CCMA is seeking reparations for injuries caused to it by Respondents due to their violations of 46 U.S.C. § 41102(c) .  \n6. The FMC has personal jurisdiction over Maersk as a “common carrier” as defined in 46 U.S.C. § 40102(7) .  \n7. The FMC has personal jurisdiction over PAC as a “MTO” as defined in 46 U.S.C.§ 40102(15) .  \n8. Respondents’ actions alleged herein constitute failures by each Respondent to establis","cbCaiklTj5OwU19n","https://ap.wps.com/l/cbCaiklTj5OwU19n","pdf",229571,13,"English","# Motion for Leave to Amend Complaint\n## Procedural background and requested amendment\n# Certificate of Service\n# Complaint (amended matter)\n## Parties and jurisdiction\n## Factual allegations","[{\"question\":\"What does CCMA request in the motion before the FMC?\",\"answer\":\"CCMA requests leave to amend its Complaint in Docket No. 22-01.\"},{\"question\":\"What changes does CCMA seek regarding the respondents?\",\"answer\":\"CCMA seeks to add Maersk A/S as a respondent and dismiss Safmarine Inc. as a respondent.\"},{\"question\":\"When is the Certificate of Service dated?\",\"answer\":\"The Certificate of Service is dated February 2, 2022.\"}]","Motion for Leave to Amend Complaint - Docket No. 22-01 - February 2, 2022 | PDF",1791048721,33]