In the Sea Tow Mobile I, the complainants receive the open form lloyd agreement from Captain Raia. On the front page and throughout the LOF, it appears that all disputes under the agreement are subject to arbitration proceedings in London, England.  The document also explicitly states that the English law, „including the English Rescue Act-1004,“ regulates all procedures. In addition, the words „No Cure, No Pay“ appear in large block letters on the front of the LOF, which means that the Salvor gets nothing for its risk and efforts if the recovery operation has not been successful. However, if the rescue operation is completed, the salvor entitles to compensation on the basis of a number of factors, including the value of the vessel, the capacity and effort required by the rescue operation and the success of that operation. See Article 13 of the LOF; Trico Marine Operators, Inc. v. Dow Chemical Co., 809 F. Supp. 440, 441-43 (E.D.La.1992) (discussion criteria for rescue bonuses). If the owner or insurer contests this claim, the disagreement will be referred to the Lloyd`s of London Arbitration Panel and any party to the agreement that wishes to be heard appoints a representative who must continue in the United Kingdom.
The respondent asserts that Lloyd`s is an expert in the field of salvage premiums.  The applicants state that they regarded the FOA as a tow contract and not as a salvage contract (CCJ Dep. of 59-60; Dep CEJ. 47-51), this belief does not change the conclusion that the questions posed by this complaint are arbiters. These two types of contracts could include a compromise clause that is easily identifiable when reading. In addition, as noted above, the complainants were aware that the agreement they signed had prompted the assistance of Captain Raia and Sea Tow to look after their vessel. Finally, the Tribunal finds that no reasonable facts could infer from this that Ms. Jones did not notice the handwritten paragraph that appeared directly at the top and bottom, on which she signed her husband`s name.
In stark contrast to the applicants` previous version, the defendant contends that Ms. Jones did read the LOF, that she had sufficient light to read the document, and that Mr. Jones had sufficient time to read it. (Declaration 3 (g) of the defendant 4, 12; Captain Robert Raia`s affidavit of September 16, 1992, 5-6).