Contract analysis

1. APPLICANT AND RESPONDENT DETAILS Applicant (Claimant): Thalassa Shipping & Logistics SA, a Société Anonyme organised and existing under the laws of the Hellenic Republic, with its registered address at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece; Greek Tax Identification Number (AFM): EL-801456729 (the "Claimant"). Respondent: Korinthian Maritime Holdings Ltd., a private limited company incorporated and reg

2. DETAILS OF THE ORDER SOUGHT The Claimant applies to this Honourable Court for an order pursuant to Section 66(1) and (2) of the Arbitration Act 1996 (the "Act") granting the Claimant permission to enforce the Final Award dated 28 June 2024 rendered in LCIA Arbitration No. 224718 (the "Award") as a judgment or order of this Court to the same effect. Specifically, the Claimant seeks the following relief: (a) Permiss

3. GROUNDS OF THE APPLICATION 3.1 The Arbitration Agreement The Claimant and the Respondent are parties to three time charter-party agreements (the "Charter-parties"), each of which is governed by English law and each of which contains an arbitration clause providing for the resolution of disputes by arbitration under the Rules of the London Court of International Arbitration (the "LCIA Rules"), with London, England,

4. EVIDENCE RELIED UPON This application is supported by the following evidence: (a) The First Witness Statement of Nikolaos Papadimitriou, Chairman and Chief Executive Officer of Thalassa Shipping & Logistics SA, dated 15 July 2024, and the exhibits thereto, in which Mr. Papadimitriou provides evidence of the background to the Charter-parties, the disputes, the arbitration proceedings, the Award, and the Respondent'

5. RESPONDENT'S DETAILS AND SERVICE The Respondent's registered address is: 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus. The Respondent's solicitors in the LCIA arbitration, and the solicitors whom the Claimant expects to be on the record for the Respondent in these proceedings, are: Harkness Whitford & Co., 12 Fetter Lane, London EC4A 1JP, United Kingdom (SRA No. 614823); for the attention of Cather

6. HEARING DETAILS The Claimant requests that this application be listed for and dealt with at an oral hearing before a Judge of the Commercial Court. The Claimant estimates that the hearing will require approximately one hour, on the assumption that the application is not contested or is contested only on limited grounds. In the event that the Respondent indicates an intention to oppose the application, the Claimant

7. RELATED APPLICATIONS The Claimant hereby gives notice that it is filing contemporaneously with this Application Notice the following additional application: (a) An application, made without notice in the first instance, for a Worldwide Freezing Order (Mareva Injunction) pursuant to Section 44 of the Arbitration Act 1996 and/or Section 37(1) of the Senior Courts Act 1981, restraining the Respondent (whether by its

8. STATEMENT OF TRUTH I believe that the facts stated in this Application Notice are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth. Signed: ________ Name: Hannah Brinkley Position: Lead Associate, Calderwood & Harkness LLP Solicitors for the

9. ADDRESS FOR SERVICE AND SOLICITOR DETAILS Claimant's Solicitors: Calderwood & Harkness LLP 45 Moorgate London EC2R 6AR United Kingdom Reference: Samuel Eklund / Hannah Brinkley Telephone: +44 (0)20 7946 0321 Email: samuel.eklund@calderwoodharkness.com / hannah.brinkley@calderwoodharkness.com DX: DX 42618 Moorgate All documents and communications in connection with this application and these proceedings should be d