Free Return of Service Executed - District Court of Delaware - Delaware

I H A ; Case 1 :08-cv-00389-SLR Document 6 Filed 07/24/2008 Page 1 of 3
UNITED STATES DISTRICT COURT
for the District of Delaware
MARNARVI SpA, as agent for JILMAR SHIPPING )
S.A., )
Plaintiff, ) `
vs. ) C.A. 1:08—cv—00389—SLR
f )
A DONALD P. KEEHAN, ARLENE KEEHAN, )
1 ADVANCED POLYMER SCIENCES, INC., )
` ADVANCED POLYMER COATINGS, LTD F/K/A )
ADVANCED POLYMER COATINGS LLC, )
)
~ Respondents. )
I Summons in a Civil Action
To:
. Advanced Polymer Sciences, Inc
c/o Delaware Secretary of State
401 Federal Services, Suite 3
Dover, DE 19907 .
A lawsuit has been filed against you.
Within 20 days after service of this summons on you (not counting the day you received
it), you must serve on the plaintiff an answer to the attached complaint or a motion under Rule
12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the
plaintiff s attorney, whose name and address are:
1 Frederick. B. Rosner, Esq.
l Duane Morris LLP
1100 North Market Street
Suite 1200
Wilmington, DE 19801
lf you fail to do so, judgment by default will be entered against you for the relief demanded in
the complaint. You also must file your answer or motion with the court.
Name o clerk of the COUII I
. , Yi f · " ·F**
Date: July 8, 2008
I Deputy ’* "s signature

I Case 1 :08-cv¤O0389-SLR Document 6 Filed 07/24/2008 Page 2 of 3
%> AO 440 (Revr O3/08) Civil Summons (Page 2)

Proof of Service
I declare under penalty of perjury that I served the summons and complaint in this case on [lg! fo l\I ZF
bw SClC°)/`lC€,Si lleiq;.
(l)personally delivering a copy of each to the individual at this place,
; or
(2) leaving a copy of each at the individual’s dwelling or usual place of abode with
who resides there and is of suitable age and discretion; or
(3) delivering a cop of each to an ent a thorized ap ointment or by law to receive it whose name is
'C rc cf S I l/l/UYC ; or
iiserxn Cc orc plrei r/9 Onowrbonnzicnu a+ T2 folpm
(4) returning the summons unexecute to the court clerk on .
My fees are $ ` for travel and $ for services, for a total of S O-O0 .
Dam Iii, i jug.;
Server’s sigiature
Qmgglm/gi; Jorma fmggss Smgcr
Printed name and title
i l *5 E l\l0vl”f\ Q}; , lm},/oh, DG l@@Ol
Server’s address

. V Case 1 :08-cv-00389-SLR Document 6 Filed 07/24/2008 Page 3 of 3 .
· IN THE UNITED STATES DISTRICT COURT if
FOR THE DISTRICT OF DELAWARE _
MARNAVI SpA, as agent for JILMAR SI·HPPlNG C.A. No. , ·· ‘··»
S.A., y V T
p _ Plaintif,
VS- coM1>LA1Nr A
l DONALD P. KEEHAN, ARLENE KEEHAN,
ADVANCED POLYMER SCIENCES, INC.;
i ADVANCED POLYMER COATINGS, LTD F-/K/A" I ’
ADVANCED POLYMER COATINGS LLC, W `
‘ Respondents.
Plaintii, Marnavi SpA ("Marnavi", as agent for Jilmar Shipping, S.A. ("Iihnar"),
by and through its undersigned attorneys, respectfully alleges as against Defendants, Advanced
Polymer Sciences, Inc. ("APS"), Advanced Polymer Coatings, Ltd. t7l Coatings, LLC ("APC”), Donald J. Keehan ("Donald Keehan") and Arlene H. Keehan ("Arlene
Keehan", and together with Donald Keehan, the "Keehans", and APS, APC and the Keehans
collectively, the "Defendants"), alleges as follows:
H INTRODUCTION ·
1. The dispute began in 1997 when Marnavi arranged for APS to apply
special coatings to the inner hull of a ship called the M/T Joran (the "]oran"). APS botched the
job and spent the next nine years fraudulently attempting to limit its liability and financial
responsibility for the damage caused to the vessel.
2. PlaintiE brings this action in support of its related petition to enforce a _
foreign arbitration award, against the defendants and their alter egos. The arbitration award
arose from Defendants’ breach of a contract with Plaintiff, as agent for Iilmar, the company that
owned the vessel the Joran, to coat the cargo tanlcs of the Joran with an allegedly superior epoxy

Case 1:08-cv-00389-SLR

Document 6

Filed 07/24/2008

Page 1 of 3

Case 1:08-cv-00389-SLR

Document 6

Filed 07/24/2008

Page 2 of 3

Case 1:08-cv-00389-SLR

Document 6

Filed 07/24/2008

Page 3 of 3