NYCLIB01/NYGSZ/122122.1 

LOVELLS LLP 

590 Madison Avenue 

New York, NY 10022 

(212) 909-0600 

Attorneys for Defendant 

Sinochem Jiangsu Corporation 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

ZIM INTEGRATED SHIPPING SERVICES, LTD., 

 Plaintiff, 

– v. – 

BELCO RESOURCES, INC., SINOCHEM JIANGSU 

CORPORATION (FORMERLY KNOWN AS SINOCHEM 

JIANGSU IMPORT & EXPORT CORPORATION), 

NANJING HUABIN FOREIGN TRADE & ECONOMICS 

CO., LTD., DRAGONTRANS SHIPPING LTD. d/b/a 

HUABANG INTERNATIONAL, INC., SINOTRANS 

NINGBO INTERNATIONAL FORWARDING AGENCY 

CO., LTD., JOHN DOE 1-10, 

 Defendants. 

07 CIV 5861 (RMB) 

(Electronically Filed) 

 

NOTICE OF: 

THE MOTION OF DEFENDANTS SINOCHEM JIANGSU CORPORATION AND 

HUABIN FOREIGN TRADE & ECONOMICS CO., LTD. TO DISMISS WITH 

PREJUDICE COUNTS II THROUGH IX OF THE SECOND AMENDED COMPLAINT 

AND TO VACATE THE RULE B ATTACHMENT 

AND 

THE MOTION OF DEFENDANT BELCO RESOURCES, INC. 

PURSUANT TO RULE (E)(4)(f) OF THE SUPPLEMENTAL ADMIRALTY RULES OF 

THE FED. R. CIV. P. TO VACATE THE RULE B ATTACHMENT 

Case 1:07-cv-05861-RMB-GWG Document 26 Filed 11/28/2007 Page 1 of 3
PLEASE TAKE NOTICE, that upon the accompanying declaration of Hillel I. Parness, the 

exhibits annexed thereto, the accompanying declaration of Chen Huanzhong, and the 

accompanying memorandum of law, Sinochem Jiangsu Corporation ("Sinochem Jiangsu"), 

making a limited appearance in this action pursuant to Fed. R. Civ. P. Supp. Admiralty R. E(8), 

by its attorneys Lovells LLP, joined by Nanjing Huabin Foreign Trade and Economics Co., Ltd. 

by their attorneys, Tisdale Law Offices, LLC, hereby move this Court, before the Honorable 

Richard Berman, United States District Judge, at the Daniel P. Moynihan United States 

Courthouse, 500 Pearl Street, New York, New York 10007, Courtroom 21D, for an order 

dismissing the Second Amended Complaint with prejudice pursuant to Federal Rule of Civil 

Procedure 12(b)(6), grounds of forum non conveniens, and vacating the Rule B Attachment 

accordingly. 

PLEASE TAKE FURTHER NOTICE, that upon the accompanying memorandum of law, 

Belco Resources, Inc., also making a limited appearance in this action, by their attorneys, 

Bennett, Giuliano, McDonnell & Perrone, LLP, hereby moves this Court, before the Honorable 

Richard Berman, United States District Judge, at the Daniel P. Moynihan United States 

Courthouse, 500 Pearl Street, New York, New York 10007, Courtroom 21D, pursuant to Rule 

(E)(4)(f) of the Supplemental Admiralty Rules of the Federal Rules of Civil Procedure to vacate 

the Rule B Attachment. 

Case 1:07-cv-05861-RMB-GWG Document 26 Filed 11/28/2007 Page 2 of 3
PLEASE TAKE FURTHER NOTICE that the two memoranda of law described herein are 

contained in a single Joint Memorandum of Law being filed this day in accordance with this 

Court’s Order of October 18, 2007. 

Dated: New York, New York 

 November 28, 2007 LOVELLS LLP 

 By: /s/ Edward T. Schorr 

 Edward T. Schorr (ES-0290) 

 Hillel I. Parness (HP-1638) 

 Matthew J. Galvin (MG 0701) 

 

 590 Madison Avenue 

 New York, New York 

 (212) 909-0600 

 Attorneys for Sinochem Jiangsu Corporation 

Case 1:07-cv-05861-RMB-GWG Document 26 Filed 11/28/2007 Page 3 of 3