Contract analysis

1. EXECUTIVE SUMMARY This is the sixth bi-weekly status report prepared by Calderwood & Harkness LLP ("C&H") in connection with the ongoing multi-jurisdictional enforcement of LCIA Award No. 224718 dated 28 June 2024 (the "Award") in favour of Thalassa Shipping & Logistics SA ("TSL") and against Korinthian Maritime Holdings Ltd. ("KMH"). This report covers the period from approximately 22 November 2024 through 6 Dece

2. ENGLAND & WALES — STATUS UPDATE 2.1 Enforcement Judgment and Set-Aside Proceedings Permission to enforce LCIA Award No. 224718 as a judgment of the Commercial Court was granted by Mr. Justice Ashworth on 2 August 2024 pursuant to section 66 of the Arbitration Act 1996 (Claim No. CL-2024-000487). The enforcement order was served on KMH and its English solicitors, Harkness Whitford & Co., in accordance with the dire

3. CYPRUS — STATUS UPDATE 3.1 Recognition and Enforcement An application for recognition and enforcement of the Award under the New York Convention (to which Cyprus is a signatory) and the Cyprus Arbitration Law (Cap. 4) was filed on 9 August 2024 in the Nicosia District Court (Case No. 2247/2024). The application was filed by our local counsel, Kyprianos Makrides & Partners ("KM&P") (Mr. Andreas Kyprianos and Ms. Na

4. SINGAPORE — STATUS UPDATE 4.1 Leave to Enforce An application for leave to enforce the Award was filed on 14 August 2024 in the Singapore High Court (Originating Summons No. 872/2024) by our local counsel, Straits Meridian LLP ("SM") (Mr. David Teo Wei Lin and Ms. Priya Subramaniam, 1 Raffles Place, #44-01 One Raffles Place Tower 2, Singapore 048616), acting on our instructions on behalf of TSL. Leave to enforce w

5. UNITED ARAB EMIRATES — STATUS UPDATE 5.1 Enforcement Application An application for enforcement of the Award was filed on 22 August 2024 in the Dubai Court of First Instance (Case No. 1893/2024) by our local counsel, Al-Rashid Hatem & Associates ("ARH") (Mr. Tariq Al-Rashid and Ms. Leila Hatem, Office 1802, Emirates Financial Towers (South Tower), DIFC, Dubai). The application was filed under UAE Federal Law No. 6

6. CUMULATIVE RECOVERY SUMMARY 6.1 Tabular Summary of Recoveries to Date The following table summarises all recoveries achieved to date across the four enforcement jurisdictions: All recovered funds have been remitted to TSL's designated recovery account at Ionian National Bank SA, 22 Stadiou Street, Athens 105 64, Greece, in accordance with TSL's standing instructions. 6.2 Outstanding Balance Calculation The outstan

7. ASSET TRACING — HARTWELL PEMBERTON LLP UPDATE Hartwell Pemberton LLP ("HP") (Ms. Rebecca Saunders and Mr. Mark Huxley, 25 Old Broad Street, London EC2N 1HN) continues to provide asset tracing and intelligence services in support of the enforcement campaign. HP's work has been instrumental in identifying enforceable assets across jurisdictions and in guiding the tactical deployment of enforcement resources. HP's up

8. OPPOSING PARTY ACTIVITY KMH is represented in the English proceedings by Harkness Whitford & Co. (Mr. Richard Harkness, Ms. Catherine Whitford, and Mr. James Thornbury, 12 Fetter Lane, London EC4A 1JP). In the Cyprus proceedings, KMH was represented by Vassiliadis & Economou LLC (Mr. Georgios Vassiliadis and Ms. Eleni Economou, 7 Stasinou Avenue, 3rd Floor, Nicosia 1060, Cyprus). KMH did not instruct local counsel

9. REMAINING ENFORCEMENT ACTIONS AND NEXT STEPS 9.1 UAE Execution Priority: High ARH are proceeding with execution against Korinthian DMCC's accounts at EGCB immediately following the conversion of the precautionary attachment to an execution attachment. The necessary procedural filings are being prepared and are expected to be submitted to the Dubai Execution Court in the period commencing 10 December 2024. The exec

10. FEE AND BUDGET STATUS The fee and budget position is summarised as follows: Calderwood & Harkness LLP fees: • Fees billed to date: approximately £3,500,000 (against the agreed fee cap of £4,200,000 for Phase 2 — Enforcement, excluding disbursements and local counsel fees) • Remaining amount under fee cap: approximately £700,000 • The budget remains on track. Given that the Cyprus and Singapore enforcement proceed

11. RISK FACTORS AND OBSERVATIONS The following risk factors and observations are brought to TSL's attention: (a) Risk of M/V *Volga Spirit* departure from Fujairah: There is a risk that the M/V Volga Spirit may depart Fujairah anchorage and proceed to a jurisdiction where arrest would be more difficult or where the legal framework for enforcement is less favourable. The vessel's AIS tracking is being monitored conti

12. RECOMMENDED CLIENT ACTIONS In light of the current status of the enforcement campaign and the matters discussed in this report, we respectfully recommend the following client actions:

1. Approve continuation of UAE enforcement and M/V *Volga Spirit* arrest: TSL is requested to confirm its approval for the continuation of enforcement proceedings in the UAE, including the execution against Korinthian DMCC's accounts at EGCB and the pursuit of the arrest of the M/V Volga Spirit. These are the two highest-priority enforcement actions and represent the most significant remaining recovery opportunities.

2. Confirm settlement instructions: TSL is requested to confirm its instructions regarding the parameters for any settlement discussions with KMH, in the event that Harkness Whitford & Co. makes a formal proposal. In particular, TSL should confirm whether it would be willing to consider any discount to the full outstanding balance (including post-award interest) or whether its position remains that full payment is re

3. Confirm receipt of Singapore vessel sale proceeds: TSL is requested to confirm receipt of the Singapore vessel sale proceeds at Ionian National Bank SA and to advise of any discrepancies in the amount received relative to the figures set out in this report.

4. Provide intelligence on KMH fleet movements and commercial activities: If TSL has any updated intelligence on KMH's fleet movements, commercial activities, or the activities of Mr. Andrei Volkov and the Volkov family that may assist the enforcement efforts, we would be grateful to receive this information. In particular, any information regarding the commercial trading status of the M/V Volga Spirit, the identity

13. NEXT REPORT Bi-Weekly Status Report #7 is expected to be issued on or about 20 December 2024. That report will cover: • Progress on the UAE execution against Korinthian DMCC's accounts at EGCB • Developments regarding the M/V Volga Spirit arrest, including the updated Northcape valuation and the outcome of ARH's assessment of UAE admiralty arrest procedure • Any settlement communications received from Harkness Wh