~eOrchis & Partners, I.LP 

8751 \V Rrowa~,l Blvd , Ste 203 

Ft Lat~derdaIe. FL. 33324 

iittornzys ot Lorr ond Proctors j,l .hm,rolty 

61 Broadmay, 2hLh Floor 

BY HAND DELIVERY 

Judge Richard M. Berman 

United States District Court 

Southern District of new York 

40 Centre Street, Courtroom 706 

RS 

New York, NY 10007 Pa 

2355 >lain Street, P.O. 186 

S. Clmtl~a~n, ,\lA 02659 

IjoS) 43z~zizi 

Re: Zim Integrated Shipping Services, Ltd. v. Belco Resources, Inc. et al. 

Southern District of New York, 07 Civ. 5861 (RMB)(GWG) 

Dear Judge: 

We are attorneys representing plaintiff Zim Integrated Shipping Services, Ltd., in connection 

with the above referenced action and we are writing you to request the authorization to file the 

declaration of Dragontrans Shipping Services, Ltd., ("Dragontrans"), a defendant located in China who 

has not yet appeared or otherwise pleaded, in support of plaintiff's opposition to defendants Sinochem 

Jiangsu Corporation and Nanjing Huabin Foreign Trade & Economics Co., Ltd.'s motion to dismiss on 

grounds of forum non conveniens. 

Although requested in early January, we only received last Monday a declaration under penalty 

of perjury from Mr. Robin Du, Dragontrans' General Manager located in Ningbo, China, in support of 

Plaintiff's opposition to the motion to dismiss. In his declaration, Mr. Du offers to make himself 

available to testify in the United States before this Court and further offers to disclose all documents in 

his possession in relation to the booking of the cargo subject to this litigation. Attached please find a 

true and accurate copy of Mr. Du's declaration. 

This declaration may certainly affect the defendants'forlrnz Iton conveniens analysis to the extent 

one of the Chinese defendants, a key prospective witness, offers to testify in this Court and perceives 

this U.S. court as an adequate forum to adjudicate this matter. 

We would like to be authorized to file Mr. Du's declaration so as to afford the defendants an 

opportunity to respond to it in their reply papers due on February 22, 2008, after this Court granted last 

Wednesday the defendants' request for a two week extension of time to file their reply. 

Case 1:07-cv-05861-RMB-GWG Document 42 Filed 02/11/2008 Page 1 of 2
Letter to Judge Berman 

February 8, 2008 

Page 2 of 2 

We thank Your Honor for his attention in this matter 

Respectfully submitted, 

By Facsimile and E-mail: 

TO: Lovells, LLP 

Attn: Edward Schorr, Esq., Hillel Parness, Esq. and Derek J. Craig, Esq. 

590 Madison Avenue 

New York NY 10022 

Tel: (2 12)-909-0600 

Fax: (2 12)-909-0660 

Attorneys for Sinochem Jiangsu Corporation 

TO: Bennett, Giuliano, McDonnell & Perr 

Attn: William R. Bennett, 111, Esq. 

225 West 34th Street 

Suite 402 

New York, NY 10 122-0402 

Tel: (646) 328-0120 I 

Fax: (646) 328-0121 

Attorneys for Relco Resources, Inc. 

TO: Tisdale & Lennon, LLC 

Attn: Thomas L. Tisdale, Esq. 

11 West 42nd St., Suite 900 

New York, NY 10036 C 

Tel: (2 12) 354-0025 

Fax: (212) 869-0067 

Attorneys for Nnnjing Huabin Foreign Trade & Economics Co., Ltd. 

U \123h-hSu\Con~ciLet Judge Berman 020708 doc 

Case 1:07-cv-05861-RMB-GWG Document 42 Filed 02/11/2008 Page 2 of 2