4. DAMAGED CARGO BY FIRE WHILE LOADING.

This is to bring to your notice that on the 13th of November in the course of loading liquid bulk containers with benzol on deck of Hold 7 of my vessel, a fire broke out about 14.00 hours, causing damage to one container.

Your stevedores' smoking undoubtedly caused the fire, through they had been repeatedly warned not to smoke during loading.

I request that the damaged cargo is to be discharged and replaced at your earliest convenience, so that the vessel may leave without delay.

5. CLAIM FOR BAD STOWAGE REJECTED.

Referring to your tale of July 14, 2021 regarding damaged to the shipment of the machinery in crates delivered to you under the B/L 81 on voyage 21 please be advise of the following.

The damaged cargo was first noticed by the Cargo Officer on June 17, at about 10.00 when he was making daily rounds inspecting lashing of the cargo in the Holds. He found some of the braces securing the crates gone, and the wire, with which he had been lashed, broken. Immediate additional lashing of the crates was impossible, owing to heavy rolling and pitching of the vessel. Any work in the hold would be endangered lives of the crew. Neither it was possible at time to evaluate the scope of the damage. The fact and extent of damage was ascertained by a P&I surveyor immediately upon the ship's arrival in Montreal.

I can not agree with you that damage was caused by improper stowage or lack of due care on the part of the ship's crew. As you can see from the enclosed documents, that the stowage had been approved by an official cargo surveyor at the port of loading and the security of lashing was regularly checked by the ship's crew on passage to the port of destination. As soon as it became possible, we made additional lashing in order to prevent further damage. Therefore, in my view, the crew has done everything that can be reasonable expected to safeguard the cargo and the damage occurred due to exceptionally severe storm with which the ship met on that voyage.

In view of the above, I reject your claim as groundless.

6. IMPROPER LASHING OF DECK CONTAINERS.

I regret to inform you that lashing of cargo by the stevedores at our two last calls at your port were carried out negligently. The bridge fittings and lashing rods were not properly tightened and mostly only assembled together owing to which the crew had to tighten up the lashing on both occasions. Usually the Dockers leave the vessel on completion of cargo operations leaving the lashing equipment lying about everywhere and without approval of the ship's Cargo Officer.

In view of the above I kindly ask you to take action and instruct the stevedores to report completion of their work to the ship's Cargo Officer and not to leave without his approval which should be formally certified by his signature. Otherwise, the ship will not leave the port until the cargo is properly lashed and secured. In this case we shall hold the stevedoring company fully responsible for all extra expenses and loses caused by such a delay of the ship.

7. CONTAINER DROPPED DURING THE LOADING.

This is to inform you that today, on July 14, 2021 during the morning shift due to negligence and incompetence of the crane operator working on Hatch 1 container SU 7171345 was dropped when it was being lifted and fell onto the quay. As a result of the fall, the container and its contents were damaged.

As the stevedoring Company refuses to reimburse the damages in full on the grounds that according to the Stevedoring Contract they have the right to limitation of liability, we kindly ask you to arrange an independent survey of the damage for tomorrow morning and invite a good lawyer specializing in cargo claims for consultations on the matter.

8. BOXES WITH CARGO BROKEN DUE TO NEGLIGENT SLINGING.

This is to inform you that today, on the 14th of July during the morning shift, while discharging the cargo tea from my vessel, due to careless handling of cargo and improper slinging 5 boxes were dropped from the sling and were totally broken.

I advise you hereby that I shall bear no responsibility for any claims in connection with the above-mentioned damage caused to the goods in the course of such inefficient discharging. At the same time, I hold the stevedoring Company, Messrs..... responsible for the damage caused and for all the consequences, which may arise therefrom, of which I kindly request you to advise the said Stevedoring Company, port Authorities, and all concerned.

9. DAMAGE TO CONTAINER.

This is to inform you that today, on the 14 of July during the morning shift, while discharging the cargo from my vessel, due to rough handling of the containers and/or inefficient of the stevedores discharging the vessel, 1 container was stroked against the coamings the Hatch 4. As result of this, the container was dented, and due to the impact, the cargo inside the container sustained considerable damage. An appropriate Statement of Facts showing details of the damage and signed by the Foreman of the Stevedoring Company is enclosed herewith.

Please note that we shall reject any possible claims for this damage as under the terms of the Stevedoring Agreement the Stevedoring Company undertakes to refund damages. I am writing on this subject to the said Stevedoring Company too.

10. BAGS TORN BY HOOKS DUE TO IMPROPER SLINGING.

This is to inform you that today, on the 14 of July 2021, during the morning shift, while discharging of cargo of rice from my vessel, due to inadmissible use of hooks 6 bags of rice were badly torn and considerable leakage and loss ensued.

I advise you hereby that I shall bear no responsibility for any claims in connection with the above-mentioned damage caused to the goods in the course of such inefficient discharging. At the same time, I hold the stevedoring Company, Messrs..... responsible for the damage caused and for all the consequences, which may arise therefrom, of which I kindly request you to advise the said Stevedoring Company, port Authorities, and all concerned.

11. PILFERAGE: STATEMENT OF FACTS

STATEMENTS OF FACTS

We, undersigned, Paul Hook Van Holland, Chief Stevedore for Vaalhaffen Stevedoring Co. and V. A. Boriskin, Cargo Officer of m/v 'Shuya' do hereby certify that on examining the box marked 'Ro***port 3472/21' shipped on board the m/v 'Shuya' under the B/L 23 and consigned to "Genex Co. ", Rotterdam stowed in Hold 1 of the above vessel we found the box broken and 100 wrist watches missing. Signed in the port of Rotterdam, Netherlands, on the 14th of July, 2021

.......... (Van Holland)

.......... (Boriskin)

12. PILFERAGE: REQUEST TO INVESTIGATE.

I regret to inform you that today, at 2.20 p. m., while the stevedores were out for the lunch break, a Watch Sailor making the inspection round in Hold 1 found a box with cargo of wrist watches the packing of which had been broken.

The Watch Officer to whom this fact was reported immediately call the Chief Stevedore. On inspecting the contents of that box, they found shortage of 100 pieces of watches. An appropriate Statement of Facts has been drawn up; the copy of this Statement is enclosed herewith. As before the commencement of discharging the contents of all holds had been inspected by a Cargo Surveyor and the goods had been found to be in proper condition and the packing to be intact, it is evidently a case of pilferage by the stevedores working in that hold.

In view of the above, I have to request you to investigate this matter.

13. CONTAINER SEAL BROKEN, CARGO STOLEN.

This is to inform you that today, on June 17th, 1992 at 10.00 my Second Mate inspecting the cargo in Hold 3 found that container SU/MMF 123245673 under B/L 5 had been broached and part of cargo of woolen shawls was missing. It is evidently a case of pilferage by the stevedores working in the hold, as prior to commencement of discharging a cargo survey had been carried out and all the seals on the containers had been found intact.

A copy of the survey report is enclosed herewith. On my orders, the container has been detained on board for a damage survey and retallying the cargo.

I kindly ask you to invite an independent surveyor for drawing up the report, I give you a formal notice hereby that I hold you fully responsible for all losses arising therefrom and ask you to take necessary action.

14. CARGO MIXED AND DAMAGED WHILE DISCHARGING.

I would like to draw your attention to inefficient and incompetent discharge of the cargo of deals and boards from my ship by the stevedores of "Haram Stevedoring Co. ". During discharge of the cargo of sawn timber from Holds 1 and 2 today and yesterday the stevedores broke two bundles of boards while discharging them into lighters and part of the cargo fell overboard into the dirty water. Besides, the steel wire sling used by stevedores chafed part of the cargo. Nevertheless my repeated requests, the foreman has not replaced it with a sling of natural or synthetic fibre. The lost of the cargo had been properly marked, as shown in the stowage plan, but while collecting boards from the broken bundles the stevedores mixed them with boards bearing different marks and numbers.

In view of the above, I warn you that I will hold the above stevedoring company responsible for all the damage and will not accept any claims for short shipment or mixed cargo after the cargo is discharged from the ship. Please advice the consignees and all concerned.

15. CARGO MIXED DURING LOADING.

This is to inform you that many of the pipes loaded into my vessel under B/Ls 21-26 consigned to "Promsyrioimport" are rusted and their ends are not covered with plastic caps.

Pipes of different diameters and marks are mixed in the barge from which they are loaded into the ship's holds.

I give you a (formal) warning hereby that I shall have to make appropriate remarks in the B/L and that the ship will not take responsibility for sorting the pipes at the port of discharge.

16. BROKEN CASES: REQUEST TO REPAIR.

This is to inform you that today, on September 11, 2021, during loading part of cargo of automobile spare parts in boxes consigned to Messrs. "Ant", Moscow, under the B/L 34, into Hold 3 some damage was caused to 6 boxes, when the crane operator struck the pallet with boxes against the coaming of the hatch square, while lowering the draft into Hold 3. The boxes have broken planks on one side and require repair.

The damage caused to the contents and the packing is described in detail in the Damage Survey Report made up by the Surveyor, invited after the incident. A copy of the report will be send to you through my agent, as soon as it is received.

I hold you responsible for the damage and all consequences thereof, and kindly ask you to have the damaged boxes repaired before completion of loading.

17. REPACKAGING OF CARGO REQUIRED.

Please note that the covers of the packed steel sheets loaded into N 2 lower hold aft part are rusted and most of the bands broken. The Mate's Receipt for this particular lot will be claused accordingly. The cover of steel package N 120 is very badly damaged and the contents exposed.

Kindly have the cover renewed and inform the authorities concerned.

18. COILS OF STEEL WIRE BADLY PACKED.

I consider it my duty to advise you in good time of the fact that the steel wire delivered for loading and addressed to Messrs. "....... " is poorly wrapped. The present wrapping consists of only one layer of burlap, which can not protect the wire from possible sweating. In the previous voyage, the consignees refused to accept part of the cargo owing to su***ce rust on the wire.

Kindly take urgent measures to secure proper wrapping of the above shipment, otherwise I will be obliged to make a remark in the B/L about insufficiency of wrapping.

19. PACKING SOILED / STAINED.

This is to inform you that today, on September 11, 2021, after discharging of the part cargo of gunny bales from Hold 3 had begun, my Cargo Officer found 8 bales in the top layer of the bales in N3 lower hold badly stained. The damage was caused by the stevedores' walking on top of the gunny bales in dirty shoes during discharging operations.

I kindly ask you to take necessary action to prevent further damage to the cargo. Please note that the ship will not be responsible for any damage caused by the stevedores.

20. FAILURE TO PROVIDE FULL LOAD.

This is to inform you that according to our computation based on the measurements of the ship's draught before and after loading the cargo of cottonseed expellers into Holds 1, 2, 4 and 5 under C/P dated Jan. 7, 2021, the weight of the above cargo is only is only 1600 metric tons, and not 1750 as per the above Charter Party.

As the time allowed for loading expires at 16.00 tomorrow, please let me know, if you wish to complete the cargo. If not, I will hold you responsible for dead freight on 150 metric tons which, according to terms of the Charter Party, at the rate of $ U. S. 50 per metric ton, is $ U. S. 650, and kindly ask you to pay the above sum before the ship's departure.

21. CLAIM FOR DEMURRAGE MONEY.

This is to inform you that due to your failure to provide cargo of linseed expellers for my vessel as fast as she could receive, as per C/P dated 03.01.21, laytime allowed for loading expired at 08.00 hours local time March 8, 2021. From that time until completion of loading, that is 15.00 hours local time, today, March 10, 2021 the vessel was on demurrage of which you had been duly warned in advance by my letter of March 3, 2021. Therefore, the time of the vessel on demurrage is 2 days and 6 hours 30 minutes, which at the rate of 500 U. S. Dollars per 1 hour of demurrage as per the C/P makes the total of 10750 U.S. Dollars.

I hold you responsible for the above sum and kindly ask you to pay it before our departure

22. DEMURRAGE, FULL CARGO NOT SUPPLIES.

This is to bring to your notice that the laydays for loading my vessel expired yesterday, on the 11th of April, 2021.

As up to date you have not supply full cargo of 5000 mat of maize to my vessel, as per Charter Party of Jan. 24, 2021, I hereby request you to let me know whether you intend to load any more cargo at all.

Please note that in accordance with the Charter Party terms under these circumstances you will be held liable for demurrage, dead freight, and damages incurred through your not supplying full cargo.

23. DISCREPANCY IN CALCULATION OF DEMURRAGE.

I have received all the documents in relation to the calculation of laytime and demurrage of my vessel in your port. I deem it my duty to contend that the amount of demurrage offered by you is much less than that claimed for by my Owners. Enclosed please find copies of our demurrage calculations

24. VERIFICATION BEFORE DEPARTURE DEMANDED.

This is to inform you that according to our calculation based on measurements of the ship's load lines made before and after loading the cargo of cottonseed expellers loaded into Holds 1, 2 and 4 under B/L 12 is only 4600 metric tons, while you claim that the total amount of the cottonseed expellers under this B/L is 4750 metric tons.

Fearing claims for short shipment, and acting under Clause 11, Part (e) of the Charter Party of June 17, 2021, I formally request to have weight verified, which under Part (b) of the same Clause will be for your account. For this purpose, I kindly ask you to invite urgently an independent cargo surveyor for verification of the weight of the cargo to be held immediately after completion of loading tomorrow.

25. SIGNING BILL OF LADING UNDER PROTEST.

This is to inform you that according to measurements of the ship's load lines before and after loading, the cargo of coal loaded into Holds 2 and 4 under B/Ls 12 and 13 is only 4600 metric tons, and not 4750 mat as indicated in your documents.

Since you contest the fact and insist on issuing clean Bills of Lading, I declare hereby that I am signing the B/Ls 12 and 13 under protest, and I will hold you responsible for short shipment in case of a claim by Receivers.

Please acknowledge receipt of this letter by signing and returning one copy of it.

26. SLOW LOADING, LAYTIME EXPIRING.

This is to inform you that loading 4750 metric tons of part of cargo of cottonseed expellers into Holds 1, 2 and 4 of the m. v. "Rover" is being carried out exceedingly slow, and that only 500 mat have been loaded up to now.

I have to remind you that taking into consideration 5 days allowed for loading by the C/P of Jan. 3, 2021 in 3 days, that is, from 08.00 local, May 3, 2021 the vessel will be on demurrage. I kindly ask you to speed up loading.

27. SLOW LOADING, REQUEST TO SPEED UP WORK.

I should like to draw your attention to the fact that loading of the pipes under B/Ls 1-20 consigned to "Promsyrioimport" is being carried out slowly. Only 950 metric tons, instead of 1600, were loaded during the first day.

Considering 5 days allowed by the Charter Party for loading, the ship will be on demurrage in 4 days. 

I kindly ask you to take necessary action to speed up the loading, and, if necessary, to use an extra cranes and detail an extra gang for simultaneous loading into two holds.

28. SLOW DISCHARGING, REQUEST TO SPEED UP WORK.

I wish to bring to your attention the fact that the rate at which the cargo is being discharged is very slow and my vessel is already on demurrage, taking into consideration five days reversible for loading and discharging.

Please make necessary arrangements to accelerate discharge and inform all those concerned of the above.

I shall be obliged if you will sign and return the attached copy of this letter in acknowledgement of its receipt.

29. SLOW LOADING, DEMURRAGE, DEAD FREIGHT.

I would like to remind you that laydays for loading my vessel expired yesterday, on March 12, 2021. Now the vessel is on demurrage.

As up to date you have not supplied the full cargo of 5000 mat of pipes to my vessel, as per Charter Party dated January 24, 2021, I hereby request you to let me know whether you intend to load any more cargo at all.

Please note that in accordance with the Charter Party terms under these circumstances you will be held liable for demurrage and dead freight to be paid in cash before the ship's departure.

Please acknowledge receipt of this letter by signing and returning one copy of it.

30. SLOW DISCHARGE, LAYTIME EXPIRING.

This is to inform you that discharge of 1750 metric tons of part of cargo of cottonseed expellers from Holds 1, 2 and 4 of m/v "Rover" is being carried

out exceedingly slow, and that only 500 mat have been discharged up to now. I have to remind you that taking into consideration 5 days allowed for discharging by the C/P of Jan. 3, 2021 in 3 days, tat is, from 08.00 local, May 3, 1991 the vessel will be on demurrage.

I kindly ask you to speed up discharging and inform the Receivers and all concerned.

31. LAYTIME EXPIRING, SHIP WAITING FOR BERTH.

This is to advise you that, as scheduled, my vessel arrived at the outer roads of your port at 05.00 LT on June 24, 2021. The Port Authorities, however, let me know that there was no berth available in the port, and they recommended me, therefore, to anchor. At present, the vessel is still lying at anchor waiting for berth.

I wish to remind you of the fact that, according to Charter Party, "time wasted in waiting for berth is counted as loading or discharging time, as the case may be". Therefore, laytime commenced to count, as provided by the Charter Party, from 1.00 p. m. June 24, 2021 and after 2 days the ship will be on demurrage.

Please inform all concerned and take necessary action.

32. DEAD FREIGHT NOT PAID.

This is to inform you that, according to our computation based on the measurements of the ship's draught taken before and after loading, the cargo of cottonseed expellers into Holds 1, 2, 4 and 5 under Charter Party dated Jan. 7, 2021, the weight of the above cargo is only 4600 metric tons, and not 4750 as per the above Charter Party.

Therefore, I hold you responsible for dead freight on 150 metric tons which, according to the terms of the Charter Party, at the rate of $U. S. 15 per metric ton, is $U. S. 225 and I kindly ask you to pay the above sum before the ship's departure.

33. FREIGHT NOT PAID IN FULL.

As provided in the C/P the goods were to be delivered to you against payment of $25000.00, representing the amount of freight to be collected on delivery the goods. In compliance with your request we began unloading yesterday at 08.00 a.m. on the understanding that the money in question would be paid in today by 10.00 a.m. to your Agent here.

Today, at 12.00 a.m., I was informed by our Agents, Messrs. "Rice Unruh" that the money had not been paid as yet. Under the circumstances I had to stop unloading and to detain a sufficient portion of goods until the said freight is paid in full, of which please take due note.

I give you a formal warning hereby that if the money is not paid today, by 16.00 at the latest, I will exercise my right of lien to cover my loses and expenses, including delay of the ship and storage of the goods subject to lien.