Amodio

MEMORANDUM **

Harry Mattocks (“Mattocks”) was the original owner of a salmon drift permit and a drift net vessel. In February 1989, Mattocks and Andrew V. Halvorsen (“Halvorsen”) signed a handwritten agreement in which Mattocks agreed to sell Halvorsen the permit and vessel for $180,000. After the Exxon Valdez oil spill, the two men renegotiated and entered into a revised agreement (“the agreement”) on April 4, 1989. The agreed price was reduced to $120,500.

In 1994, Mattocks filed with the Exxon Valdez Qualified Fund (“Fund”) administrator a claim for the $59,500 he lost when he sold the vessel and permit at a discount after the oil spill. The Fund administrator determined that Mattocks was due only $137.41. When this amount was issued to him, he rejected it as insufficient. Mattocks died in 1998 without resolving his claim.

In 1999, the heirs of Mattocks (“Mattocks Heirs”) filed a supplemental claims form for lost income, permit devaluation, and vessel devaluation pursuant to the court-approved Plan of Distribution of Allocations to the Prince William Sound Salmon Drifter Claim Category (“S03E Plan”). The administrator of the Fund denied all three claims. The court-appointed…