9-89, at 799 (2d ed.1975) (footnote omitted). If the amount of security provided by the LOU is insufficient to satisfy a judgment, the court ordinarily may authorize the re-arrest of the vessel only if the amount of the original security was obtained through fraud or mistake. See Moore v. M/V ANGELA 353 F.3d 376, 385-386 (5th Cir.2003) (“While it is true that a district court may require ‘further security’ at any time, we interpret the phrase to mean substitute or replacement security (e.g., when a surety has become insolvent) rather than additional security, except where the vessel was released by fraud, misrepresentation, or mistake of the court.” (internal citation omitted) (emphasis in original)); Industria Nacional Del Papel, CA. v. M/V ALBERT F, 730 F.2d 622, 626 (11th Cir.1984) (<HOLDING>). Although in this case there was no fraud or
holding misrepresentation claim to be preempted recognizing that a release is subject to avoidance on grounds such as fraud or mistake recognizing fraud to be a known misrepresentation or a nondisclosure holding that a mistake sufficient to justify rearrest must be tinged with fraud or misrepresentation holding negligent misrepresentation sufficient