GEORGE B. FREEHILL 

WILLIAM L. JUSKA. JR. 

JAMES L. ROSS' 

ERIC E. LENCK 

JOHN J. WALSH' 

PATRICK J. BONNER' 

PETER J. GUTOWSKI 

MARK F. MULLER 

WAYNE D. MEEHAN' 

DON P. MURNANE. JR.0 

THOMAS M. RUSSO 

THOMAS M. CANEVARI' 

MICHAEL FERNANDEZ* 

JOHN F. KARPOUSIS'r 

MICHAEL E. UNGER.? 

WILLIAM J. PALLAS' 

GINA M. VENEZIA"n 

LAWRENCE J. KAHN' 

BARBARA G. CARNEVALE* 

MANUEL A. MOLINA 

JUSTIN T. NASTRO' 

PAMELA L. SCHULTZ'"' 

DANIEL J. FITZGERALD''~ 

MICHAEL C. ELLIOT 

' ALSO ADMITTED IN NEW JERSEY ' ALSO ADMITTED IN CONNECTICUT 

,%ALSO ADMITTED IN WASHINGTON. D.C. 

-ALSO ADMITTED IN LOUISIANA 

1,AW OFB'ICES OF 

FRNEIIILI~ HOGAN & MAHAR LTJ1' 

80 PINE STREET 

NEW YOlIK, N.Y. 10005-1759 

TELEPHONE (21 2) 425-1 900 

FACSIMILE (212) 425-1901 

E-MAIL: reception@freehiIl.com 

NEW JERSEY OFFICE 

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JERSEY CITY, N.J. 07306 

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May 29,2007 

Our Ref 207-07lWLJ 

BY HAND 

Honorable Richard M. Berman 

United States District Judge 

Daniel Patrick Moynihan 

United States Courthouse 

500 Pearl St., Room 650 

New York, NY 10007 

Re: NB Shipping Ltd. v. Genuine Shipping Corp. 07-3237 (RMB) 

Dear Judge Berman: 

We represent Plaintiff in this matter and write to request an adjournment of the initial 

conference which is currently scheduled for June 4, 2007, atMpm. This is our first request 

for an adjournment. 2:.W p. 

This matter involves a claim by Plaintiff for breach of a maritime contract of charter 

party which is subject to London arbitration. The merits will be decided in London and there 

will be no discovery or other substantive actions in connection with this New York action. This 

action was commenced for purposes of obtaining security in connection with the London 

arbitration. Plaintiffs complaint thus included a request for an attachment pursuant to 

Supplemental Admiralty Rule B of the Federal Rules of Civil Procedure, which relief was 

granted by the Court exparte, as provided for in Rule B. 

Rule B specifically provides for an attachment as ex parte relief, and under Local 

Admiralty Rule B.2, we are not required to provide notice of these proceedings to the defendant 

until after property has been actually restrained. Thus far, Plaintiff 

restrain any pr 

daily basis. If 

NYDOCS 11284060 1 

Case 1:07-cv-03237-RMB Document 4 Filed 05/29/2007 Page 1 of 2
The Honorable Richard M. Berman 

May 29,2007 

Page 2 

restrained) by providing notice of an initial conference, the purpose for which the attachment 

was sought and this Court's order of attachment would be defeated. 

Accordingly, because the dispute is subject to London arbitration and because assets of 

the defendant have not yet been restrained triggering the notice provision of Rule B, we submit 

that there is no need for a scheduling conference and respectfully ask that June 4 conference be 

adj oumed. 

Respectfully submitted, 

FREEHILL HOGAN & MAHAR, LLP 

GUI-() v*t.(+d. 

80ORD ED 

Date: ?A**( flb"LwU 

Rlchard M. Bermam, U.S.D.J. 

Case 1:07-cv-03237-RMB Document 4 Filed 05/29/2007 Page 2 of 2