Contract analysis

1. Heading and Procedural Information This Application Notice is filed by the Claimant, Thalassa Shipping & Logistics SA (a Société Anonyme organised under the laws of the Hellenic Republic, registered at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece, GEMI No. 146832507000), by its solicitors, Calderwood & Harkness LLP, 45 Moorgate, London EC2R 6AR (SRA No. 582917), Reference: SE/LO/HB/PG/TSL-Enforcement. This a

2. Relief Sought The Claimant respectfully seeks the following relief:

1. An order varying the Worldwide Freezing Order (the "WFO") made by Mr. Justice Ashworth on 16 July 2024 (granted without notice to the Respondent) and continued with modifications by the order of Mr. Justice Ashworth on the return date of 30 July 2024, so as to reduce the maximum sum restrained under Paragraph 5 of the WFO from £108,600,000 (one hundred and eight million six hundred thousand pounds sterling) to £15

2. An order that the WFO, as so varied, shall remain in full force and effect in all other respects, including but not limited to the ancillary asset disclosure obligations imposed upon the Respondent, the penal notice endorsed upon the WFO, and all provisions regarding the Respondent's obligation not to remove from England and Wales or in any way dispose of, deal with, or diminish the value of any of its assets worl

3. An order providing for the costs of and incidental to this application.

3. Grounds of the Application The grounds upon which this application is made are as follows:

1. The WFO was originally granted on 16 July 2024, without notice to the Respondent, in the sum of £108,600,000, restraining Korinthian Maritime Holdings Ltd. from removing from England and Wales or in any way disposing of, dealing with, or diminishing the value of any of its assets worldwide up to that amount. The WFO was granted upon the evidence of Nikolaos Papadimitriou, director and authorised representative of

2. The WFO was continued with modifications by Mr. Justice Ashworth on the return date of 30 July 2024, at which hearing the Respondent appeared through counsel instructed by Harkness Whitford & Co. and did not dispute the continuation of the WFO, save as to certain limited modifications regarding ordinary course of business exceptions.

3. The WFO was granted in support of the enforcement of LCIA Award No. 224718 dated 28 June 2024, in which the Tribunal awarded the Claimant the total sum of £96,450,000 in damages and pre-award interest, together with £12,150,000 in the costs of the arbitration (reflecting 85% allocation to the Respondent), yielding a combined total of £108,600,000.

4. Since the grant of the WFO, the Claimant has conducted a multi-jurisdictional enforcement campaign in England and Wales, Cyprus, Singapore, and the United Arab Emirates, and has further received a voluntary payment from the Respondent. The total sum recovered as a result of those enforcement proceedings and the voluntary payment is £96,590,000.

5. The maximum restrained sum under the WFO should be reduced to reflect the amounts actually recovered, in accordance with the principle that the Court's jurisdiction to maintain a freezing order is limited to the amount of the outstanding obligation. It is well established that a freezing order should not restrain assets in excess of the amount of the claim: see Customs and Excise Commissioners v. Anchor Foods Ltd.

6. The Claimant acknowledges its duty of full and frank disclosure and its obligation to inform the Court of material changes in circumstances, including in particular the partial satisfaction of the underlying judgment. The Claimant makes this application in fulfilment of that duty. The Claimant further acknowledges its continuing obligation under the WFO to notify the Respondent and the Court of any further materia

7. The outstanding balance of approximately £15,617,726.03 (calculated as at 15 March 2025 and inclusive of post-award interest) continues to justify the maintenance of the WFO at the reduced level. The Respondent has demonstrated a persistent pattern of asset dissipation and corporate restructuring, as found by this Court in its judgment of 16 July 2024 granting the original WFO, and the continuing risk of further d

4. Evidence in Support This application is supported by the following evidence:

1. The Witness Statement of Hannah Brinkley dated 15 March 2025, Lead Associate at Calderwood & Harkness LLP, setting out in detail the recoveries achieved across all jurisdictions, the calculation of the remaining balance, the continuing risk of dissipation, and the justification for the maintenance of the WFO at the reduced level. The witness statement is filed together with Exhibits HB-1 through HB-12.

2. The original evidence filed in support of the WFO, being the Witness Statement of Nikolaos Papadimitriou dated 14 July 2024, and the exhibits thereto, all of which were before the Court on 16 July 2024 and on the return date of 30 July 2024, and which established the basis for the original grant of the WFO.

3. The asset tracing reports and post-award asset movement analysis prepared by Hartwell Pemberton LLP (25 Old Broad Street, London EC2N 1HN), forensic accountants and asset tracing specialists instructed by the Claimant's solicitors, which confirm the quantum of recoveries to date and identify remaining assets against which enforcement may be pursued. The relevant report, dated 25 November 2024, is exhibited to the

5. Service This application, together with the draft order and the supporting Witness Statement of Hannah Brinkley with all exhibits, will be served upon Harkness Whitford & Co. at 12 Fetter Lane, London EC4A 1JP, as solicitors on the record for the Respondent, Korinthian Maritime Holdings Ltd. The Claimant invites the Respondent to consent to the order sought in the terms of the draft order annexed hereto. In the ev

I. The total amount recovered across all jurisdictions and by way of the voluntary payment is £96,590,000 (ninety-six million five hundred and ninety thousand pounds sterling), broken down as follows: The outstanding balance is calculated as follows: Total Award and Costs: £108,600,000 Post-award interest accrued on £96,450,000 at 5.25% per annum simple from 29 June 2024 to 15 March 2025 (a period of 260 days): £96,4

1. The Worldwide Freezing Order made by Mr. Justice Ashworth on 16 July 2024 and continued with modifications on 30 July 2024 (the "WFO") shall be and is hereby varied such that the maximum sum restrained under Paragraph 5 of the WFO is reduced from £108,600,000 (one hundred and eight million six hundred thousand pounds sterling) to £15,617,726.03 (fifteen million six hundred and seventeen thousand seven hundred and

2. For the avoidance of doubt, the figure of £15,617,726.03 represents the estimated outstanding balance as at 15 March 2025, calculated as set out in Recital I above. The revised maximum restrained sum shall be subject to further variation, whether upward or downward, to account for: (a) post-award interest continuing to accrue at the rate of 5.25% per annum simple on the unpaid portion of the Award (being such port

3. Save as varied by Paragraphs 1 and 2 of this Order, the terms of the Worldwide Freezing Order dated 16 July 2024 (as continued and modified on 30 July 2024) shall remain in full force and effect, including without limitation: (a) the prohibition on the Respondent from removing from England and Wales or in any way disposing of, dealing with, or diminishing the value of any of its assets, whether they are in or outs

4. The Claimant shall, within 7 days of any further recovery or receipt of funds (howsoever arising) in partial or full satisfaction of the Award, the Costs, or the post-award interest, notify the Court (by filing a letter with the Clerk to Mr. Justice Ashworth, or such other Judge as may have conduct of this matter) and the Respondent's solicitors, Harkness Whitford & Co. (at 12 Fetter Lane, London EC4A 1JP), in wri

5. The Claimant shall, within 14 days of any such further recovery, apply to this Court for a further variation of the maximum restrained sum under the WFO (as varied by this Order) to reflect the reduced outstanding balance, and shall file a draft order in the terms sought. In the event that the parties are able to agree the revised figure, they may submit a consent order for approval on the papers. Paragraph 4 — Li

6. Either party shall have liberty to apply to vary or discharge this Order or the WFO (as varied by this Order) on not less than 3 clear days' notice to the other party, such notice to be given in writing to the other party's solicitors at the addresses set out above. Paragraph 5 — Costs

7. The costs of and incidental to this application shall be costs in the enforcement proceedings, to be assessed on the standard basis if not agreed. SCHEDULE — SUMMARY OF AMOUNTS BY THE COURT ________________________________________ The Honourable Mr. Justice Ashworth Date: ________ PART THREE: WITNESS STATEMENT OF HANNAH BRINKLEY IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES COMMERC

1. I am a Lead Associate in the International Disputes and Enforcement team at Calderwood & Harkness LLP, solicitors for the Claimant in these proceedings. I am a solicitor of the Senior Courts of England and Wales, having been admitted to the Roll in 2016 (SRA No. 658412). I hold an LLM in International Commercial Law from University College London (2015). I have had day-to-day conduct of the enforcement proceedings

2. I make this witness statement in support of the Claimant's application for partial discharge of the Worldwide Freezing Order (the "WFO") in Claim No. CL-2024-000487. Unless otherwise stated, the facts and matters set out in this statement are within my own knowledge and are true. Where the facts and matters are not within my own knowledge, I identify the source of the information and believe them to be true. Where

3. There is now produced and shown to me a paginated bundle of exhibits marked "HB-1" to "HB-12", to which I will refer in this statement. Background The Award and the WFO

4. On 28 June 2024, the Tribunal in LCIA Arbitration No. 224718 (comprising Sir Malcolm Fenton-Clarke as Presiding Arbitrator, Professor Athena Drakopoulos as Co-Arbitrator, and Dr. Henrik Dalmqvist as Co-Arbitrator, with Ms. Fiona Beckett as Tribunal Secretary) issued its Final Award (the "Award"), ordering the Respondent to pay to the Claimant a total of £96,450,000 in damages and pre-award interest. The Award furt

5. The Award arose from charter-party disputes concerning three dry-bulk carriers — the M/V Aegean Fortuna (IMO 9784521), the M/V Crimson Horizon (IMO 9801334), and the M/V Volga Spirit (IMO 9756892) — all of which were the subject of English-law governed time charter-party agreements containing LCIA arbitration clauses with London as the seat of arbitration. The disputes arose from the Respondent's wrongful early re

6. On 16 July 2024, this Court (Mr. Justice Ashworth) granted a Worldwide Freezing Order against the Respondent, without notice, in the sum of £108,600,000, upon the evidence of Nikolaos Papadimitriou, a director and authorised representative of Thalassa, who set out in his witness statement dated 14 July 2024 the grounds for the application, including the existence of a good arguable case (the Award having already b

7. On 2 August 2024, Mr. Justice Ashworth granted the Claimant permission to enforce the Award as a judgment of this Court pursuant to section 66 of the Arbitration Act 1996. A copy of the order granting permission is exhibited hereto at Exhibit HB-3.

8. On 19 August 2024, the Respondent filed an application to set aside the Award under sections 68 and 69 of the Arbitration Act 1996. On 11 October 2024, Mr. Justice Ashworth dismissed the Respondent's set-aside application in its entirety, with costs awarded to the Claimant on the indemnity basis. A copy of the order dismissing the set-aside application is exhibited hereto at Exhibit HB-4. Enforcement Campaign and

9. Since the grant of the WFO and the permission to enforce the Award, Calderwood & Harkness LLP has coordinated a multi-jurisdictional enforcement campaign on behalf of the Claimant, in conjunction with local counsel in Cyprus (Kyprianos Makrides & Partners, 15 Grivas Digenis Avenue, Nicosia 1066, Cyprus), Singapore (Straits Meridian LLP, 1 Raffles Place, #44-01 One Raffles Place Tower 2, Singapore 048616), and the

10. On 5 August 2024, the Claimant applied for and obtained an interim third-party debt order against Meridian Trust Bank Ltd. (50 Lombard Street, London EC3V 9EA) in respect of accounts held by the Respondent at that institution. On 3 September 2024, a final third-party debt order was made by Deputy Master Frobisher, and the sum of £18,720,000 was garnished from the Respondent's accounts at Meridian Trust Bank Ltd.

11. On 9 August 2024, the Claimant filed an application in the Nicosia District Court for recognition and enforcement of the Award under the New York Convention and Cyprus International Commercial Arbitration Law (Case No. 2247/2024). On 12 August 2024, a freezing injunction was obtained over the Respondent's shares in Oceangate Ventures Ltd. (Cyprus Registration No. HE 401293) and the Respondent's bank accounts held

12. On 14 August 2024, the Claimant filed an application for leave to enforce the Award in the Singapore High Court pursuant to the International Arbitration Act (Cap. 143A) (Originating Summons No. 872/2024). Leave to enforce was granted on 6 September 2024. On 18 October 2024, a garnishee order absolute was made against Pinnacle Bank (Singapore) Ltd. (6 Battery Road, #20-01, Singapore 049909), and the sum of SGD $3

13. On 20 August 2024, the vessel M/V Crimson Horizon (IMO 9801334, Handymax Bulk Carrier, 37,500 DWT, Liberian flag), owned by Korinthian Bulkers (Singapore) Pte. Ltd., was arrested in Singapore waters pursuant to an in rem warrant of arrest. On 15 November 2024, the vessel was sold by judicial sale for USD $22,800,000. On 2 December 2024, the vessel sale proceeds, in the amount of approximately £18,330,000 (at prev

14. On 22 August 2024, the Claimant filed an enforcement application in the Dubai Court of First Instance under UAE Federal Law No. 6 of 2018 and the New York Convention (Case No. 1893/2024). On 28 August 2024, a precautionary attachment was obtained over the accounts of Korinthian DMCC (Unit 3407, Almas Tower, JLT, Dubai), a subsidiary of the Respondent, held at Emirates Gulf Commercial Bank PJSC (Gate Village 3, DI

15. On 3 February 2025, the Respondent made a voluntary payment of £7,400,000 to the Claimant by wire transfer to Calderwood & Harkness LLP's client account. The payment was made following a without prejudice save as to costs offer communicated by Harkness Whitford & Co., and was accompanied by a letter from Harkness Whitford & Co. confirming that the payment was to be applied in partial satisfaction of the Award and

16. The total amount of the Award and Costs is £108,600,000, comprising £96,450,000 in damages and pre-award interest and £12,150,000 in costs.

17. Post-award interest accrues at the rate of 5.25% per annum simple on the principal award sum of £96,450,000, running from 29 June 2024 (the day following the date of the Award) until payment. For the purposes of this application, I have calculated the post-award interest accrued from 29 June 2024 through 15 March 2025, a period of 260 days, as follows: £96,450,000 × 0.0525 × (260 ÷ 365) = £3,607,726.03

18. The calculation of the outstanding balance as at 15 March 2025 is therefore as follows: Grand Total Owed: £108,600,000 + £3,607,726.03 = £112,207,726.03 Less: Total Recovered: £96,590,000 Outstanding Balance: £112,207,726.03 − £96,590,000 = £15,617,726.03 I note that post-award interest continues to accrue on the unpaid portion of the Award, and accordingly the outstanding balance may require further adjustment o

19. The risk of dissipation which justified the original grant of the WFO continues. This Court, in its judgment of 16 July 2024, found that there was solid evidence of a real risk of dissipation, based upon the Respondent's conduct in moving assets out of reach of potential creditors, establishing new corporate vehicles in opaque jurisdictions, and taking steps to restructure its fleet ownership in anticipation of t

20. I refer in this regard to the post-award asset movement analysis prepared by Hartwell Pemberton LLP and dated 25 November 2024, a copy of which is exhibited hereto at Exhibit HB-12. That report identifies a pattern of further asset transfers by the Respondent and its subsidiaries to entities connected to Andrei Volkov, the ultimate beneficial owner and de facto director of KMH, including the transfer of managemen

21. The Claimant continues to pursue enforcement against remaining identifiable assets of the Respondent and its subsidiaries. In particular, the Claimant is actively pursuing enforcement against the vessel M/V Volga Spirit (IMO 9756892, Panamax Bulk Carrier, 76,400 DWT, Cyprus flag), owned by Dnepr Shipholding Inc. (BVI Company No. 2014876), which was last reported at Fujairah anchorage in the United Arab Emirates.

22. For the reasons set out above, I respectfully request that this Court make the order sought in the terms of the Draft Order for Partial Discharge of Worldwide Freezing Order annexed to the Application Notice. The proposed variation is proportionate and necessary: it reduces the restrained sum to reflect the recoveries achieved, in compliance with the Claimant's duties to the Court, whilst maintaining the freezing

23. I believe that the facts stated in this witness statement 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: ________ HANNAH BRINKLEY Lead Associate, Calderwood & Harkness LLP DATED: 15 March 2025 EXHIBIT LIST The following exhibi