Contract analysis

1. Executive Summary This is Bi-Weekly Status Report #10 in respect of the cross-border enforcement of LCIA Award No. 224718 dated 28 June 2024 (the "Award") in the matter of Thalassa Shipping & Logistics SA ("TSL" or the "Client") v. Korinthian Maritime Holdings Ltd. ("KMH"). This report covers the period from approximately 24 January 2025 through 7 February 2025 and provides a comprehensive update on all enforcemen

2. Summary of Recovery to Date — All Jurisdictions 2.1 Recovery Table The following table sets out all recoveries achieved to date on a jurisdiction-by-jurisdiction basis, identifying the enforcement mechanism employed, the amounts recovered in both local currency and GBP equivalent, and the date or dates on which recovery was effected: All currency conversions have been calculated at the prevailing exchange rates at

3. Developments Since Last Report 3.1 UAE Recovery Completion (14 January 2025) As reported in Status Report #9 (dated 24 January 2025), enforcement proceedings in the UAE were progressing well following the grant of the enforcement order by the Dubai Court of First Instance (Case No. 1893/2024) on 20 November 2024. The enforcement order was obtained pursuant to UAE Federal Law No. 6 of 2018 on Arbitration and the pr

4. Jurisdiction-by-Jurisdiction Status 4.1 England & Wales Court: Commercial Court, Rolls Building, Royal Courts of Justice, London (Claim No. CL-2024-000487, before Mr. Justice Ashworth) Status: Enforcement substantially complete; WFO remains in force. The English enforcement proceedings were the first commenced following the rendering of the Award. Permission to enforce the Award as a judgment of the Commercial Cou

5. Remaining Enforcement Options and Outstanding Balance 5.1 M/V *Volga Spirit* (IMO 9756892) The M/V Volga Spirit is a Panamax Bulk Carrier of 76,400 DWT, registered under the Cyprus flag. The registered owner is Dnepr Shipholding Inc. (BVI Company No. 2014876), whose registered agent is Vantage Corporate Services Ltd., Road Town, Tortola, British Virgin Islands. As noted in Section 4.2 above, Dnepr was previously h

6. Fees and Budget Update 6.1 Calderwood & Harkness LLP Fees The agreed fee cap for the enforcement phase of this matter is £4,200,000, exclusive of disbursements and local counsel fees. The fee cap was established in the engagement letter dated 5 July 2024 and amended by the supplemental fee agreement dated 18 September 2024. The current position is as follows: The remaining enforcement activities — which include th

7. Risk Assessment and Key Considerations We have identified the following key risks and considerations relevant to the remaining enforcement activities and the matter as a whole: Risk of KMH Challenge or Further Opposition: LOW All set-aside and opposition applications brought by KMH across the relevant jurisdictions have been dismissed. The English set-aside application under sections 68 and 69 of the Arbitration A

8. Recommended Next Steps Based on the foregoing analysis, we recommend that the following steps be taken in the near term:

1. Instruct ARH to prepare standby arrest documentation for M/V *Volga Spirit* in UAE (Fujairah). Given that the vessel is currently at Fujairah anchorage, this represents the most immediate and practical enforcement opportunity. ARH should be instructed to prepare the necessary documentation and to be ready to file on short notice upon receiving the green light from TSL and this firm.

2. Maintain active vessel-tracking for M/V *Volga Spirit* and identify alternative arrest ports. Northcape Maritime Advisory should continue to monitor the vessel's movements in real time and provide immediate alerts if the vessel departs Fujairah or arrives at any port where an arrest may be effected. Alternative arrest port strategies should be developed for key trading ports in New York Convention jurisdictions.

3. Instruct Hartwell Pemberton LLP to provide an updated report on sub-charterer receivables for attachment. HP should be asked to provide a comprehensive update identifying all attachable receivables, including debtor identity, jurisdiction, estimated amount, and recommended attachment mechanism. This will allow TSL to pursue attachment as a supplementary recovery avenue.

4. Prepare and file an application for partial discharge of the Worldwide Freezing Order in the Commercial Court. The application should seek a reduction of the maximum restrained sum from £108,600,000 to the approximate outstanding balance of £15,617,726.03 (subject to adjustment for continuing interest). Calderwood & Harkness will liaise with Harkness Whitford & Co. to seek consent to the variation.

5. Update the interest calculation memorandum to reflect all payments received. Calderwood & Harkness and Hartwell Pemberton will prepare a joint memorandum setting out the precise post-award interest accrual on a declining-balance basis, taking account of all payments received and the alternative allocation methodologies.

6. Begin matter closing preparations. These include the preparation of a final fee summary, the implementation of document retention procedures in accordance with TSL's instructions and Calderwood & Harkness's professional obligations, and the coordination of local counsel file closures in Cyprus, Singapore, and the UAE (subject to the resolution of the M/V Volga Spirit enforcement).

7. Schedule a call with TSL to discuss closing strategy. We recommend that a call be arranged with Mr. Papadimitriou and Ms. Christodoulou at the earliest convenient opportunity to discuss the following matters: (a) whether TSL wishes to pursue the remaining balance aggressively (i.e., proceed with the M/V Volga Spirit arrest and sub-charterer receivable attachment) or to transition to a reduced-scope monitoring post

9. Next Report Bi-Weekly Status Report #11 is expected to be issued on or around 21 February 2025. The report will cover developments from 7 February to 21 February 2025, including any progress on the M/V Volga Spirit arrest documentation, the HP sub-charterer receivables update, and any further communications from HW. The target matter close date remains 15 March 2025, subject to the resolution of the outstanding en

1. Recovery Confirmation — UAE (email from Tariq Al-Rashid, Al-Rashid Hatem & Associates, dated 14 January 2025)

2. Letter to Harkness Whitford & Co. confirming receipt of voluntary payment of £7,400,000 (dated 5 February 2025)

3. Updated Multi-Jurisdictional Recovery Tracker (as at 7 February 2025) PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION. This document and all enclosures are protected by legal professional privilege and are provided solely for the use of the named addressees. Unauthorised disclosure, distribution, or copying is strictly prohibited. Calderwood & Harkness LLP is a limited liability partnership registered