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Themis Court Simulations
DOCUMENT # 1
TESTIMONY
Pamenos Chatoyer
47 Penrod Street
Dakar, Senegal
January 13, 2017
President Judge Thomas A. Mensah
International Tribunal For the Law of the Sea
Hamburg
Your Honor:
I am a fully licensed port officer with 10 years' experience here in Dakar, Senegal. For the last
five years I've provided my best services to carry out oil filling system in this very port.
On 24 October 2015 at 10.00 a.m., I have personally witnessed that the M/V “Saiga” oil
tanker which was flying the flag of Saint Vincent and the Grenadines left Dakar, under the
command of Captain Orlov.
As I have checked, there were 15 people in the crew: The Master and crew of the ship were
all of Ukrainian nationality. There were also three Senegalese nationals who were employed
as painters. Their names are as follows:
1. Stefan Orlov
2. Anatoly Hlynka
3. Myron Kacharovsky
4. Volodymyr Krawtchouk
5. Mykhailo Kulik
6. Yakiv Krein
7. Marko Marchenko
8. Oleksandr Banakh
9. Nikolay Budker
10. Gersh Bogolyubov
11. Isaak Pylchykov
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12. Ivan Sinelnikiv
13. Didier Camara
14. Mamadou Diagne
15. Seckou Lo-Diouf
Before it set sailed to the ocean, the M/V Saiga was fully laden with approximately 5,400
metric tons of gas oil which I made the filling operation in the flesh. In this respect, my
professional experience clearly tells me that such an amount is totally normal for an oil
bunker in M/V Saiga’s size; because oil tanker capacity is estimated based on a measure of
how much mass a ship is carrying or can safely carry.
Furthermore, the M/V Saiga were filled with gas oil in an amount that could satisfy the
refueling of almost 50 fishing vessels since the gas oil that was loaded in M/V Saiga is
sufficient in terms of nautical science.
In conclusion, I believe that M/V Saiga was in due process as an oil bunker vessel just as the
very fundamental principles of maritime science proves.
Sincerely,
Pamenos Chatoyer
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DOCUMENT 2
Eleni S’candal: A Tool for Human Smuggling
By Stelios Vassilikos
BBC News, Greece
13 July 2013
The Greek ship Eleni S is impounded by the Hellenic Coast Guard for the sixth time for
human smuggling.
Eleni S is a fishing vessel famous for being used for human smuggling.
The ship has already been docked to the port five times because of human trafficking.
However, the owner of this vessel, Leonidas Evangelatos, has rendered the necessary payment
each time to take the ship from the port and did not give up renting it out to the human
smugglers.
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Five days ago, in 8th July 2013, at around midnight, Eleni S is impounded again by the
Hellenic Coast Guard, near Kos Island. When the Coast Guard approached to the ship, they
saw a dramatic seen, a fishing vessel full of refugees who are totally vulnerable. After that,
the Coast Guard has seized the ship, arrested the crew and carried out the official proceedings
for the miserable passengers of Eleni S.
Additionally, in his statement made to the press in 11th July 2013, Mr. Evangelatos
explained the reason behind his actions, saying: "The only reason I rent Eleni S to those guys
is that they offered four times more than the other customers". But his justification was
questioned; public opinion considers his action unjustifiable and unreasonable for the fact that
he should have been much more careful as a ship-owner.
Whereas the Eleni S’s crew is under arrest, the future of the refugees who were
seeking to reach Europe remains uncertain.
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DOCUMENT 3
Appiah N’Diaye
27 Rude de Paris Street
Saint Louis, Senegal
January 23, 2017
President Judge Thomas A. Mensah
International Tribunal For the Law of the Sea
Hamburg
Your Honor,
I am the captain of the fishing vessel named Kriti. On 27 October, last year, we were trying to
gain our livelihood in the exclusive economic zone of Guinea. Our vessel run out of oil and
we demanded oil supply from the oil banker Saiga. Saiga crew members were acting careless
and I had to warn them twice so that we would not face an accident.
I am an experienced Captain and from my previous experiences I am well aware how tragic
accidents occur as the result of not initiating the necessary attention. The process of oil supply
is a dangerous thing, and in vessels like our and Saiga, old technology is used, to not pour oil
to seas we need to be extra careful.
Normally this process takes about 1 hour. Yet, the crew members managed to complete the oil
supply process in about 45 minutes. Then they have sailed towards the vessel Eleni S. It has
taken my notice that they spend about 4 hours together. I thought they have made a mistake
during the oil supply and I worried. I knew that, if oil is supplied to the seas, there would be
no meaning to fish in the area. So that tried to communicate with both of them via wireless yet
both vessels did not respond. Then, I informed the officials of Guinea.
The police forces started tracking Eleni S and Saiga after having my testimony.
Sincerely,
Appiah N’Diaye
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