Doxsee Sea Clam Co., Inc. v. Christian Brown, 13 F.3d 550 (2d Cir. 1994). · Go Syfert
Doxsee Sea Clam Co., Inc. v. Christian Brown, 13 F.3d 550 (2d Cir. 1994). Cases Citing This Book View Copy Cite
“moreover, the itemization of medical bills in excess of 110,000 clearly was sufficient to inform doxsee of the reasonable possibility that a, substantial damages claim .for personal injury in excess of 350,000 would be brought by brown.”
126 citation events (100 in the last 25 years) across 24 distinct courts.
Strongest positive: In re Henry Marine Service, Inc. (nyed, 2015-09-29)
Treatment trajectory · 1995 → 2026 · click a year to view as-of
1995 2010 2026
Top citers, strongest first. 40 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) In re Henry Marine Service, Inc. (5×) also: Cited as authority (rule), Cited "see"
E.D.N.Y · 2015 · signal: cf. · quote attribution · 1 verbatim quote · confidence high
moreover, the itemization of medical bills in excess of 110,000 clearly was sufficient to inform doxsee of the reasonable possibility that a, substantial damages claim .for personal injury in excess of 350,000 would be brought by brown.
discussed Cited as authority (rule) In the Matter of the Complaint of Ed Seganti
2d Cir. · 2025 · confidence medium
We do not require “exacting specificity in a notice of claim to a vessel owner” but instead employ a “broad and flexible standard of review—reading letters of notice in their entirety and considering their ‘whole tenor’—when determining if sufficient notice was given.” Doxsee Sea Clam Co., Inc. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994) (quoting In re Allen N. Spooner & Sons, Inc., 253 F.2d 584, 586 (2d Cir. 1958)).
cited Cited as authority (rule) In the Matter of the Complaint of William Gremler, Jr.
E.D.N.Y · 2025 · confidence medium
Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 553 (2d Cir. 1994).
discussed Cited as authority (rule) Wienold v. Vargas
N.D. Ill. · 2024 · confidence medium
But the Seventh Circuit also considers “a letter sent to a ship- owner by a claimant … sufficient to trigger the six-month period if (1) it informs the shipowner of an actual or potential claim (2) which may exceed the value of the vessel (3) and is subject to limitation.” Id. (citing Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir.1994)).
examined Cited as authority (rule) In the Matter of the Complaint of Ed Seganti (3×) also: Cited "see, e.g."
E.D.N.Y · 2024 · confidence medium
The six-month period begins to run when a petitioner receives notice “of an actual or potential claim . . . which may exceed the value of the vessel.” Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994).
discussed Cited as authority (rule) Interstate Navigation Company
D.R.I. · 2024 · confidence medium
This additional requirement, not explicit in the language § 30529 or in Rule F, has been applied by courts outside of the First Circuit. , 33 F.4th 1157, 1164 (9th Cir. 2022) (“We hold that the phrase “written notice of a claim” imposes three requirements: the notice must (1) be in writing, (2) clearly state that the victim intends to bring a claim or claims against the owner, and (3) include at least one claim that is reasonably likely to be covered by the Limitation Act.”); , 918 F.3d 1323, 1330-31 (11th Cir. 2019) (requiring a sufficient written notice of a claim to “reveal a ‘…
discussed Cited as authority (rule) Johnson v. The Christeni Group LLC
N.D. Cal. · 2022 · confidence medium
“In the usual case in which all federal-law claims 10 || are eliminated before trial, the balance of factors to be considered under the pendent jurisdiction 11 doctrine -- judicial economy, convenience, fairness, and comity -- will point toward declining to 12 || exercise jurisdiction over the remaining state-law claims.” Sanford v. MemberWorks, Inc., 625 5 13 F.3d 550, 561 (9th Cir. 2010) (internal quotation, citation, and brackets omitted).
examined Cited as authority (rule) William Martz v. Andrew Horazdovsky (3×) also: Cited "see"
9th Cir. · 2022 · confidence medium
For that reason, courts have agreed “that letters sent by claimants to vessel owners may constitute notice of claim.” Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994); accord Orion Marine Constr., 918 F.3d at 1333 n.4 (noting “that informal written notice, such as a letter sent by a claimant or his attorney, will 14 MARTZ V.
discussed Cited as authority (rule) In re Talbott (2×)
N.D. Ind. · 2021 · confidence medium
L.L.C., 672 F.3d 310, 319 (5th Cir. 2012) (catastrophic event allowed for inference of claim value); Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554-55 (2d Cir. 1994) (itemized list of medical insurance claims provided reasonable probability).
discussed Cited as authority (rule) In the Matter of the Complaint of Lance Staughton, owner of S/V Bat Out of Hell, for Exoneration from or Limitation of Liability
W.D. Wash. · 2021 · confidence medium
Sufficient Notice Under the Reasonable Possibility Test 7 Under the first test, a claimant provides sufficient notice if he or she “informs the vessel 8 owner of an actual or potential claim . . . which may exceed the value of the vessel . . . and is 9 subject to limitation.” Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994). “[T]he 10 written notice of a claim must reveal a ‘reasonable possibility’ that the claim made is one subject 11 to limitation.” In re McCarthy Bros.
discussed Cited as authority (rule) In Re: Las Vegas Boat Harbor, Inc.
D. Nev. · 2021 · confidence medium
Alaska, Nov. 3, 2020). 17 16 Id. & 8 n.78 (collecting authority). 18 17 Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994) (quoting In re Allen N. Spooner & Sons, Inc., 253 F.2d 584, 586 (2d Cir. 1958)). 19 18 Id. & 8 n.79 (collecting authority). 20 19 Id. 20 In re Complaint of McCarthy Bros.
examined Cited as authority (rule) In the Matter of the Complaint of William Martz (6×) also: Cited "see, e.g."
D. Alaska · 2020 · confidence medium
Relying on an 44 Docket 25 at 14. 45 Docket 25 at 23. 46 Docket 25 at 14. 47 Orion Marine Constr., Inc. v. Carroll, 918 F.3d 1323, 1330 (11th Cir. 2019) (quoting Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994)).
examined Cited as authority (rule) DEVILS HOLE JETBOAT, LLC and NIAGARA JET ADVENTURES, LLC, as Owners or Owners Pro Hav Vice of a 2014, 33 foot M/V \GONAGO:GO:H III\"" (3×) also: Cited "see"
W.D.N.Y. · 2020 · confidence medium
Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994).
discussed Cited as authority (rule) Hornstein v. Giordano
E.D.N.Y · 2020 · confidence medium
The six-month period begins to run once the petitioner receives notice “of an actual or potential claim . . . which may exceed the value of the vessel[.]” Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994) (citations omitted); In re Henry Marine Serv., Inc., 136 F. Supp.3d at 408 (internal quotation marks and citations omitted).
discussed Cited as authority (rule) Brava Cruz, LLC v. Torres (2×) also: Cited "see"
S.D. Tex. · 2020 · confidence medium
RLB Contracting, 773 F.3d at 605 (quoting Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994)).
examined Cited as authority (rule) New York State Marine Highway Transportation, LLC (3×) also: Cited "see"
N.D.N.Y. · 2020 · confidence medium
Doxsee Sea Clam Co., Inc. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994).
cited Cited as authority (rule) Bullet Services, Inc. v. Brown
E.D.N.Y · 2019 · confidence medium
Brown, 13 F.3d 550, 554 (2d Cir. 1994) (citations omitted); In re Miller ’s Launch, Inc., No. 10-CV-0872, 2010 WL 3282627 , at *2 (E.D.N.Y.
cited Cited as authority (rule) Gene Brown v. Edwards and Richter, L.L.P.
5th Cir. · 2019 · confidence medium
RLB Contracting, 773 F.3d at 605 (rejecting a requirement of “magic words” or “exacting specificity” in the communication (quoting Doxsee Sea Claim Co. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994))).
discussed Cited as authority (rule) Orion Marine Construction, Inc. v. Mark Dawson
11th Cir. · 2019 · confidence medium
The Second and Seventh Circuits have said the same thing, see McCarthy , 83 F.3d at 829 (" [T]he written notice of claim must reveal a 'reasonable possibility' that the claim made is one subject to limitation." (emphasis added)); Doxsee , 13 F.3d at 554 ("Notice will be sufficient if it informs the vessel owner of an actual or potential claim ... which may exceed the value of the vessel ... and is subject to limitation." (emphasis added)).
cited Cited as authority (rule) RLB Contracting, Inc. v. Butler
5th Cir. · 2014 · confidence medium
Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir.1994). 27 .
examined Cited as authority (rule) In re Waterfront License Corp. (3×) also: Cited "see, e.g."
S.D. Fla. · 2005 · confidence medium
E.g., Doxsee, 13 F.3d at 554 (finding that letter from claimant’s attorney to vessel owner’s insurance adjuster was sufficient to trigger the six month statutory prescription of 46 App. U.S.C. § 185 because vessel owner had clothed insurance adjuster with apparent authority); Diamond, 247 F.2d at 607 (noting that “the written notice of claim given to or filed with the agent designated by the owner established the time from which the six months’ limitation period started to run”); Kiewit Pacific, Co., 1994 WL 446967 at *3 (noting that when claimant sent notice to vessel owner’s att…
discussed Cited as authority (rule) Paradise Divers, Inc. v. Kevin R. Upmal
11th Cir. · 2005 · confidence medium
In Doxsee Sea Clam Co. v. Brown, 13 F.3d 550 (2d Cir.1994), the Second Circuit concluded that “[n]otice will be sufficient if it informs the vessel owner of an actual or potential claim ... which may exceed the value of the vessel ... and is subject to limitation.” 13 F.3d at 554 (internal citations omitted).
cited Cited as authority (rule) Group Therapy, Inc. v. White
W.D.N.Y. · 2003 · confidence medium
Doxsee Sea Clam Co., Inc. v. Brown, 13 F.3d 550, 554 (2d Cir.1994).
examined Cited as authority (rule) In Re the Complaint of UFO Chuting of Hawaii, Inc. (4×) also: Cited "see"
D. Haw. · 2001 · confidence medium
The Second Circuit has explained that notice “will be sufficient if it informs the vessel owner of an actual or potential claim which may exceed the value of the vessel, and is subject to limitation.”' Dox see, 13 F.3d at 554 (internal citations omitted).
discussed Cited as authority (rule) Alumax Inc. and Consolidated Subsidiaries v. Commissioner
Tax Ct. · 1997 · confidence medium
Co., 391 A.2d 196, 197-198 (Del. 1978), with Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 553 (2d Cir. 1994), and Carte Blanche (Singapore) PTE., Ltd., v. Diners Club Intl., Inc., 758 F. Supp. 908, 919 (S.D.N.Y. 1991). - 104 - dated Subs".
discussed Cited as authority (rule) Alumax Inc. v. Commissioner
Tax Ct. · 1997 · confidence medium
Co., 391 A.2d 196, 197-198 (Del. 1978), with Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 553 (2d Cir. 1994), and Carte Blanche (Singapore) PTE., Ltd. v. Diners Club Intl., Inc., 758 F. Supp. 908, 919 (S.D.N.Y. 1991).
cited Cited as authority (rule) In the Matter of the Complaint of McCarthy Brothers Company/clark Bridge, as Owner Pro Hac Vice of Barge No. Aeb1 for Exoneration From or Limitation of Liability
7th Cir. · 1996 · confidence medium
Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir.1994).
cited Cited as authority (rule) In re the Complaint of McCarthy Bros.
7th Cir. · 1996 · confidence medium
Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir.1994).
cited Cited as authority (rule) Moog v. Hilton Hotels Corp.
S.D.N.Y. · 1995 · confidence medium
Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir.1994).
cited Cited "see" In re Talbott
N.D. Ind. · 2021 · signal: see · confidence high
See Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir. 1994).
discussed Cited "see" Fish N Dive LLC
D. Haw. · 2021 · signal: accord · confidence high
Accord Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 553 (2d Cir. 1994) (noting that the district court vacated the stay of the state court liability action when it dismissed the limitation action as untimely).
cited Cited "see" In Re Complaint of Wepfer Marine, Inc. for Exoneration From or Limitation of Liability
W.D. Tenn. · 2004 · signal: see · confidence high
See Doxsee Sea Clam Co., Inc. v. Brown, 13 F.3d 550, 554 (2d Cir.1994); Complaint of Beesley’s Point Sea-Doo, Inc., 956 F.Supp. 538, 540-41 (D.N.J.1997).
discussed Cited "see" Trustees of the American Federation of Musicians & Employers' Pension Fund v. Steven Scott Enterprises, Inc.
S.D.N.Y. · 1999 · signal: see · confidence high
See Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 553 (2d Cir.1994) (“An agent has apparent authority when conduct by the principal leads a third party to believe that the agent has authorization to act on behalf of the principal.”).
examined Cited "see" Chemical Bank v. Affiliated FM Insurance (3×)
unknown court · 1999 · signal: see · confidence high
See Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 553 (2d Cir.1994) (“An agent has apparent authority when conduct by the principal leads a third party to believe that the agent has authorization to act on behalf of the principal.”).
discussed Cited "see" Chemical Bank v. Affiliated Fm Insurance Co. (2×)
unknown court · 1999 · signal: see · confidence high
See Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 553 (2d Cir.1994) ("An agent has apparent authority when conduct by the principal leads a third party to believe that the agent has authorization to act on behalf of the principal.").
examined Cited "see" In Re the Complaint of Beesley's Point Sea-Doo, Inc. (6×)
D.N.J. · 1997 · signal: see · confidence high
See Doxsee Sea Clam Co., Inc. v. Brown, 13 F.3d 550, 554 (2d Cir.1994).
cited Cited "see, e.g." Lopez v. Renee Baker
D. Nev. · 2019 · signal: see also · confidence medium
App. P. 22; 9th Cir. R. 22-1; Allen v. 12 Ornoski, 435 F.3d 946, 950-951 (9th Cir. 2006); see also United States v. Mikels, 236 13 F.3d 550, 551-52 (9th Cir. 2001).
discussed Cited "see, e.g." Leonard v. Optimal Payments Ltd. (In Re National Audit Defense Network)
Bankr. D. Nev. · 2005 · signal: see also · confidence medium
“Unless otherwise agreed, authority to appoint a subagent is inferred from authority to conduct a transaction for the principal for the performance of which the agent is to be responsible to the principal if:... (b) the agent is a corporation, partnership or other organization.” Restatement (Second) of Agency § 80(b); see also Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir.1994); Manley v. AmBase Corp., 121 F.Supp.2d 758, 772 (S.D.N.Y.2000).
discussed Cited "see, e.g." Norfolk Dredging Co. v. Wiley
E.D. Va. · 2005 · signal: see also · confidence medium
See, e.g., Spooner, 253 F.2d at 586 (holding that “the whole tenor of the letter” suggests that it constitutes a notice of claim); see also Doxsee Sea Clam Co., *949 Inc. v. Brown, 13 F.3d 550, 554 (2d Cir.1994); Beesley’s Point Sea-Doo, Inc., 956 F.Supp. at 541 .
discussed Cited "see, e.g." Manley v. AmBase Corp.
S.D.N.Y. · 2000 · signal: see also · confidence medium
“Unless otherwise agreed, authority to appoint a subagent is inferred from authority to conduct a transaction for the principal for the performance of which the agent is to be responsible to the principal if: ... (b) the agent is a corporation, partnership or other organization.” Id. § 80(b); see also Doxsee Sea Clam Co. v. Brown, 13 F.3d 550, 554 (2d Cir.1994).
Retrieving the full opinion text from the archive…
DOXSEE SEA CLAM CO., INC., Plaintiff-Appellant,
v.
Christian BROWN, Defendant-Appellee
422, Docket 93-7525.
Court of Appeals for the Second Circuit.
Jan 3, 1994.
13 F.3d 550
John Ingram, New York City (Lisa A. Scognamillo, Burlingham Underwood, New York City, of counsel) for plaintiff-appellant., Paul C. Matthews, New York City (L. Kevin Sheridan, Smithtown, NY, of counsel) for defendant-appellee.
Altimari, Elfvin, Miner.
Cited by 42 opinions  |  Published
MINER, Circuit Judge:

Plaintiff-appellant Doxsee Sea Clam Co., Inc. (“Doxsee”) appeals from an order entered in the United States District Court for the Southern District of New York (Sand, J.), denying Doxsee’s motion to strike the affirmative defense of untimeliness interposed by defendant-appellee Christian Brown. The defense was pleaded in Brown’s answer to Doxsee’s petition, filed pursuant to 46 U.S.C. app. §§ 183-186 (1988), for exoneration from, or limitation of, liability for injuries allegedly suffered by Brown aboard a Doxsee-owned fishing vessel. The order also dismissed the petition as time-barred under 46 U.S.C. app. § 185. For the reasons that follow, we affirm.

BACKGROUND

On November 19, 1989, Browm was injured aboard Doxsee’s vessel F/V DAY STAR, a clam dredger on which he was employed as a deckhand. Brown sustained a laceration on his forehead as a result of being struck by a removable metal “bin board” used to prevent clams from falling off a conveyor on the vessel. Brown was treated for his injury at a local hospital and returned to work the following day.

Doxsee’s President, Robert L. Doxsee, Jr., immediately was made aware of Brown’s injury by the captain of the DAY STAR, who also informed Mr. Doxsee of the specific details of the accident. Mr. Doxsee then called his insurance representative at Mariner’s Insurance Agency (“Mariner’s”) in accordance with his regular practice. International Marine Underwriters (“IMU”), Dox-see’s insurance carrier, thereafter retained Maritime Adjusters, Inc. (“Adjusters”) to investigate Brown’s claim.

On January 17, 1990, Brown developed lower back pain while working aboard the DAY STAR and was examined by an orthopedic specialist. On January 29, Brown returned to the specialist and was admitted later that same day to South Nassau Communities Hospital, where he remained until February 11. He was transferred to St. Francis Hospital on February 11 for tricus-pid heart valve surgery. Brown was suffering from a staph infection and bacterial endo-carditis caused by the staph infection. The St. Francis Hospital history sheet records the laceration on Brown’s forehead as a possible source of infection.

After Brown had been hospitalized for about two weeks, his father phoned Mr. Dox-see and inquired whether worker’s compensation would be paid to his son. Mr. Doxsee referred Brown’s father to Mariner’s. A subsequent inquiry from South Nassau Communities Hospital concerning a bill for services rendered in connection with Brown’s treatment likewise was referred to Mariner’s. While in the hospital, Brown retained an attorney, Paul Berg, whose inquiries Mr. Doxsee also directed to Mariner’s. Thereafter, by letter dated March 6, 1990, Frank Sweeney, a claims adjuster from Adjusters, wrote to Berg:

Dear Attorney Berg:
[*552] Enclosed please find a medical authorization form for Mr. Brown to sign and return with a complete list of all treating physicians, hospitals, etc. so that I may obtain a medical history on what is going on.
The original problem as reported to this office was a slight groin pull from pushing a clam cage that, two weeks later, escalated into heart surgery, etc.
With the enclosed signed, I should be able to get the information necessary to properly review the file and attempt to determine what underwriters are going to do.
If you have any questions, do not hesitate to call.
Sincerely,
s/Frank A. Sweeney
Maritime Claims Adjuster

Brown was discharged from the hospital on April 11, 1990 following open heart surgery involving the removal of a portion of a heart valve.

On April 25, 1990, Berg wrote to Adjusters, referencing “Your File 6-90F” and “Christian Brown,” the same file number and “Claimant” referenced in Sweeney’s letter of March 6, 1990. Following these references, Berg’s letter stated:

Dear Sirs[:]
Please be advised that this firm represents Mr. Christen [sic] in this matter of his alleged accident aboard the ship Day Star, owened [sic] and operated by Doxee [sic] Sea Clamb [sic] Co., Inc.

Sweeney admits receiving this letter.

In an Affidavit in Opposition to Doxsee’s motion to strike the affirmative defense of time-bar submitted by Paul C. Matthews, Brown’s present attorney, Matthews stated that Berg and Sweeney “remained in contact with each other” and that Sweeney made arrangements for a representative “from Mariner’s to meet with Berg to inspect the DAY STAR, and particularly the bin board involved in the accident of November 19, 1989.” The inspection aboard the DAY STAR took place in May of 1990.

On May 29,1991, Matthews wrote to Sweeney in a letter referencing “Christian Brown v. Doxsee Sea Clam Company.” Sweeney admits that he received the letter. Matthews began the letter as follows:

Dear Mr. Sweeney:
Please be advised that I have been retained by Christian Brown to represent him in a claim against your assured, Dox-see Sea Clam Company.

Matthews went on to state that, pursuant to the ship owner’s maintenance and cure obligations, Doxsee should be paying Brown’s medical and hospital expenses, as well as maintenance for the time when Brown was not hospitalized. Matthews listed the hospital bills that were in his file, totalling over $110,000, and demanded payment for all outstanding bills.

The first notice sent directly to Doxsee was a letter dated May 18, 1992 from Matthews that was received on May 20. In the letter, Matthews advised Doxsee that he represented Brown, who had become ill as a result of contaminated lacerations he sustained while aboard the DAY STAR in December of 1989. [1] Matthews indicated that he had contacted Adjusters in May of 1991 requesting maintenance and cure, which had yet to be paid. He warned that, unless maintenance and cure were paid immediately, “it [was his] intention to commence suit on [Brown’s] behalf not only for maintenance and cure, but also for damages under the Jones Act and the General Maritime Law.” Subsequently, on June 18, 1992, Brown commenced a personal injury action in Supreme Court, Bronx County, seeking $21,000,000 in damages for injuries allegedly sustained while he was a deckhand aboard the DAY STAR.

On November 17, 1992, Doxsee commenced the proceeding giving rise to this appeal. By the proceeding, Doxsee seeks exoneration from, or limitation of, liability, pursuant to 46 U.S.C. app. § 185 and Rule F of the Supplemental Rules for Certain Admiralty and Maritime Claims. Section 185 provides that a vessel owner may limit its liability on a substantive claim against it to the value of its interest in the vessel and pending freight. Here, the verified complaint sought[*553] $21,000,000 in damages; Doxsee’s interest in the DAY STAR was approximately $350,000. In his answer, served on or about January 4, 1993, Brown asserted that the action was time barred because more than six months had passed since Doxsee received notice of Brown’s claim.

Doxsee moved to strike this affirmative defense on January 21, 1993. In affidavits submitted to the district court in support of the motion, both Mr. Doxsee and Sweeney stated that, although Adjusters received notice of claim, it never was authorized by Doxsee or anyone else to accept notice on Doxsee’s behalf. The district court denied the motion, dismissed the action as untimely and vacated the stay of Brown’s state court action. The district court determined that Adjusters had apparent authority to accept notice of claim on behalf of Doxsee and that notice of claim, therefore, was received by Doxsee upon Sweeney’s receipt of the May 29, 1991 letter from Matthews. The district court found apparent authority based on Sweeney’s letter of March 6, 1990 notifying Brown that Adjusters had opened a file on the claim and based on Mr. Doxsee’s referral of Brown’s father and Berg to Adjusters. The district court, disagreeing with Doxsee’s argument that the extent of the damages was not apparent from the injuries suffered, noted that the Sweeney letter acknowledged that Brown had undergone heart surgery. The district court also observed that the itemization of medical bills in the Matthews letter of May 29, 1991 indicated the magnitude of the claim. Finally, the district court rejected Doxsee’s argument that the letters sent by Berg and Matthews referred only to claims for maintenance and cure, which are not subject to the time limitation at issue here. The district court found that, while neither letter referred to damages other than for maintenance and cure, the letters did not expressly limit Brown’s claim to those remedies; moreover, the ongoing investigation of the incident was inconsistent with such a position because claims for maintenance and cure essentially are no-fault claims.

DISCUSSION

The question concerning the timeliness of Doxsee’s petition relates only to the April 25, 1990 letter from Berg to Sweeney and the May 29, 1991 letter from Matthews to Sweeney. The parties do not dispute that Dox-see’s filing of the petition in this action was timely with regard to the letter dated May 18, 1992 from Matthews to Doxsee, but was tardy with regard to both the April, 1990 and May, 1991 letters.

Our analysis here proceeds in two parts. First, we must determine whether receipt of the letters by Sweeney constitutes written notice to Doxsee as required by 46 U.S.C. app. § 185. Second, if Doxsee received notice, we must examine whether it was a notice of claim sufficient to satisfy section 185.

1. Adjuster’s Authority to Receive Notice of Claim

Section 185, which governs a vessel owner’s petition for limitation of liability, provides in relevant part: “The vessel owner, within six months after a claimant shall have given to or filed with such owner written notice of claim, may petition a district court of the United States of competent jurisdiction for limitation of liability....” 46 U.S.C. app. § 185 (emphasis added). Here, the letters that Brown argues comprised the notice of claim were sent not to Doxsee, but to Sweeney, the marine claims adjuster employed by Adjusters. Therefore, if Brown is to prevail, it must be determined that Adjusters had authority to receive notice of claim on behalf of Doxsee. It is settled that a notice of claim may be received by an agent of the vessel owner. See Diamond v. Beutel, 247 F.2d 604, 607 (5th Cir.1957). Both Sweeney and Mr. Doxsee gave statements that neither Adjusters nor Sweeney had authority to accept notice of claim on behalf of Doxsee. However, we agree with the district court’s determination that Sweeney and Adjusters had apparent authority to receive Brown’s notice of claim.

An agent has apparent authority when conduct by the principal leads a third party to believe that the agent has authorization to act on behalf of the principal. 99 Commercial St., Inc. v. Goldberg, 811 F.Supp. 900, 906 (S.D.N.Y.1993); Lawyer’s [*554] Fund for Client Protection v. Manufacturer’s Hanover Trust Co., 153 Misc.2d 360, 581 N.Y.S.2d 133, 134 (Sup.Ct.1992). Apparent authority is dependent on verbal or other acts by the principal, of which the third party is aware, which reasonably give the appearance that the agent has authority to conduct a particular transaction. Greene v. Hellman, 51 N.Y.2d 197, 433 N.Y.S.2d 75, 80, 412 N.E.2d 1301, 1306-07 (1980). If a third party reasonably relies upon such acts, the principal will be bound by the conduct of his agent. See Legal Aid Soc’y v. Economic Opportunity Comm’n, Inc., 521 N.Y.S.2d 833, 835 (App.Div. 3d Dep’t 1987).

Here, Mr. Doxsee referred inquiries by both Brown’s father and Berg to Mariner’s, Doxsee’s insurance agency. Apparently, the agency referred the inquiries to the underwriter, IMU, which then retained Adjusters. If Adjusters was not Doxsee’s agent, it was a sub-agent of the entity designated by Doxsee to handle matters relating to Brown’s injury. See Restatement (Second) of Agency § 80 (1958) (authorization of sub-agency inferred if agent is business organization or appointment of sub-agent for performance is usual and principal has reason to know that agent employs sub-agents). Here, it is apparent that Mr. Doxsee would have reason to know that a claims adjuster would be employed by IMU to investigate Brown’s injuries. In either event, Adjusters, via Sweeney, was holding itself out and acting as an agent of Dox-see, and Mr. Doxsee’s statements clothed Adjusters with apparent authority to act in this capacity. This conclusion is supported by the correspondence commenced by Sweeney in March of 1990 and by the inspection of the DAY STAR by Mariners in May of 1990, events of which Mr. Doxsee was aware and in which he apparently acquiesced. Therefore, since Adjusters had apparent authority to receive notice of claim by Brown, and Sweeney acknowledges receipt of the relevant letters, Doxsee’s argument that it did not receive written notice prior to May of 1992 cannot succeed. We now turn to the question of whether the letters constituted sufficient notice of claim.

2. Sufficiency of Notice

Section 185 does not indicate what type of writing or form is necessary to satisfy its requirement of written notice of claim. Nevertheless, it is settled that letters sent by claimants to vessel owners may constitute notice of claim. See, e.g., In re Allen N. Spooner & Sons, Inc., 253 F.2d 584, 586 (2d Cir.), cert. dismissed, 358 U.S. 30, 79 S.Ct. 9, 3 L.Ed.2d 48 (1958); In re Spearin, Preston & Burrows, Inc. (“Lavinia D.”), 190 F.2d 684, 686 (2d Cir.1951); Complaint of Okeanos Ocean Research Found., Inc., 704 F.Supp. 412, 414 (S.D.N.Y.1989). Doxsee argues that the letters sent to Sweeney are so lacking in detail that they fail to give sufficient notice. However, this Court has not required exacting specificity in a notice of claim to a vessel owner. Rather, we have employed a broad and flexible standard of review — reading letters of notice in their entirety and considering their “whole tenor”— when determining if sufficient notice was given. See Spooner, 253 F.2d at 586. Notice will be sufficient if it informs the vessel owner of an actual or potential claim, id., which may exceed the value of the vessel, In re Morania Barge No. 190, Inc., 690 F.2d 32, 34 (2d Cir.1982), and is subject to limitation, Lavinia D., 190 F.2d at 686. Here, we conclude that Matthews’ letter of May 29, 1991 to Sweeney was notice of claim sufficient to trigger the six-month limitations period of section 185.

Matthews’ letter made specific reference to “a claim against” Doxsee by Brown. It specifically referred to Matthews having been “retained” to represent Brown against Doxsee and the “Re:” line of the letter was styled in the manner of an actual, present controversy: “Christian Brown v. Doxsee Sea Clam Company.” Moreover, the itemization of medical bills in excess of $110,000 clearly was sufficient to inform Doxsee of the reasonable possibility that a substantial damages claim for personal injury in excess of $350,000 would be brought by Brown. See Spooner, 253 F.2d at 586 (letter informing petitioner that claimant “may” press claim constituted notice of claim). Such a claim for damages would be subject to the limitation imposed by section 185. Even if we were to[*555] conclude that the letter was ambiguous as to the amount that would be sought by Brown, the burden to seek clarification falls upon Doxsee. See id. at 586-87 (Hand, J., concurring) (“[I]t is indeed reasonable to require [petitioner] to make the claimant define his position.... That ought to throw upon the owner the risk that the claimant would in fact assert the claim which he spoke of only as possible.”). Here, Doxsee did not respond to Matthews’ letter until it filed its petition for limitation or exoneration in November of 1992—eighteen months after Sweeney’s receipt of the letter. Upon reviewing Matthews’ letter of May 29, 1991 to Sweeney, it is apparent from its tenor that its import was to inform Doxsee that Brown was considering a claim that exceeded the value of the DAY STAR and, thus, we conclude that it provided sufficient notice of claim as required by section 185.

CONCLUSION

For the foregoing reasons, the judgment of the district court is hereby affirmed.

1

. This date was erroneous. Brown sustained the lacerations in November of 1989.