Contract analysis

1. Introduction and Purpose of This Letter We write to you on behalf of our client, Thalassa Shipping & Logistics SA ("TSL"), a Société Anonyme organised under the laws of the Hellenic Republic, with its registered and principal offices at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece (Tax Identification Number / AFM: EL-801456729). Calderwood & Harkness LLP ("C&H") acts as TSL's international counsel and has do

2. Background to the Dispute and Arbitration We set out below a detailed summary of the factual and procedural background to the dispute. This summary is intended to provide KM&P with sufficient context to prepare the enforcement and freezing applications. The full evidentiary record is contained in the Award itself and the supporting documentation enclosed with this letter. 2.1 The Charter-Party Agreements TSL enter

3. Enforcement Actions Already Commenced in Other Jurisdictions TSL is pursuing a comprehensive, multi-jurisdictional enforcement strategy, coordinated centrally by C&H from London, in order to maximise the prospects of full recovery of the amounts due under the Award. Enforcement proceedings are being commenced or prepared simultaneously in the following jurisdictions: (a) England and Wales; (b) Republic of Cyprus (

4. Identification of KMH's Cyprus Assets — Targets for Enforcement The following section identifies the principal Cyprus-based assets against which enforcement is to be pursued. The information set out below is derived from publicly available corporate registry records, the Hartwell Pemberton asset tracing report, and TSL's own commercial knowledge. 4.1 Korinthian Maritime Holdings Ltd. — Direct Cyprus Presence KMH i

5. Instructions — Application for Recognition and Enforcement 5.1 Legal Basis The recognition and enforcement application should be filed on the basis of the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 10 June 1958) (the "New York Convention"), as implemented in the domestic law of the Republic of Cyprus through the International Commercial Arbitration Law of 1987 (Law 101/1987

1. Certified copy of LCIA Final Award No. 224718, dated 28 June 2024, bearing the signatures of the three arbitrators and certified by the LCIA Registrar (Enclosure 1);

2. Certified copies of the three charter-party agreements containing the LCIA arbitration clauses, dated 15 March 2019, 22 January 2020, and 10 June 2021, respectively (Enclosure 2);

3. Certificate from the LCIA Registrar confirming the authenticity of the Award and its issuance in accordance with the LCIA Rules (Enclosure 3);

4. Certified English-to-Greek translations of the Award and the arbitration agreements, prepared by an accredited translator — please confirm whether such translations are required by the Nicosia District Court, or whether the English originals will be accepted without translation (if translations are not required, we will withdraw this enclosure to avoid unnecessary expense) (Enclosure 10, if applicable);

5. Sealed copy of the Worldwide Freezing Order granted by Mr. Justice Ashworth on 16 July 2024 in the Commercial Court (CL-2024-000487) (Enclosure 4);

6. Preliminary Asset Tracing Report from Hartwell Pemberton LLP dated approximately 1 August 2024 (for information and for use in the freezing injunction application — an interim version is enclosed; the final version, incorporating the most recent tracing findings, will follow under separate cover) (Enclosure 8). Please advise at the earliest opportunity if any additional documentation, legalisation, apostille, or t

6. Instructions — Freezing Injunction Application (Interim Relief) 6.1 Scope of Freezing Relief Sought Simultaneously with, or immediately following the filing of, the enforcement application, we instruct KM&P to apply for an interim freezing injunction (mareva-type order) in the Nicosia District Court, restraining KMH from dealing with, disposing of, transferring, charging, encumbering, or otherwise diminishing the

7. Execution and Forced Sale Mechanism Looking beyond the recognition and enforcement stage, and in anticipation of the enforcement order being granted, we wish to understand and plan for the execution phase — that is, the process by which the judgment resulting from the enforcement of the Award will be executed against KMH's Cyprus assets. We would be grateful if KM&P could provide a preliminary memorandum at your e

8. Coordination and Reporting As noted above, this enforcement campaign is being coordinated centrally by Calderwood & Harkness LLP from London, with enforcement actions proceeding in parallel across multiple jurisdictions. Effective coordination between all counsel teams is critical to the success of the campaign and to the avoidance of inconsistent or duplicative steps. We therefore request that KM&P observe the fo

9. Fees and Billing Please provide your fee proposal for this engagement at the earliest opportunity. The fee proposal should address the estimated fees for each of the following phases: (a) the enforcement (recognition) application, including preparation, filing, and any ex parte hearing; (b) the freezing injunction application, including preparation, filing, and any ex parte and inter partes hearings; (c) oppositio

10. Enclosures Enclosed with this letter (via international courier, expected delivery 8 August 2024) are the following documents:

1. Certified copy of LCIA Final Award No. 224718, dated 28 June 2024;

2. Certified copies of the three charter-party agreements dated 15 March 2019, 22 January 2020, and 10 June 2021;

3. LCIA Registrar's certificate confirming the authenticity of the Award;

4. Sealed copy of the Worldwide Freezing Order (CL-2024-000487, dated 16 July 2024, as continued on 30 July 2024);

5. Sealed copy of the section 66 Application Notice (CL-2024-000487, dated 15 July 2024);

6. Order granting permission to enforce the Award as a judgment (dated 2 August 2024);

7. Interim third-party debt order against Meridian Trust Bank Ltd. (dated 5 August 2024);

8. Preliminary Asset Tracing Report from Hartwell Pemberton LLP (interim version; final version to follow under separate cover);

9. Corporate registry extracts for Korinthian Maritime Holdings Ltd. (HE 387421) and Oceangate Ventures Ltd. (HE 401293), obtained from the Cyprus Department of Registrar of Companies and Official Receiver; and

10. Certified English-to-Greek translations of the Award and arbitration agreements (if applicable — see our request for confirmation at Section 5.3 above as to whether translations are required by the court; if not, this enclosure will be withdrawn). Please confirm receipt of all enclosures upon delivery.

11. Urgency We wish to emphasise in the strongest possible terms the extreme urgency of this instruction. The evidence before us — and before the English Commercial Court, which has already found a real risk of dissipation — demonstrates that KMH is actively engaged in steps to place its assets beyond the reach of TSL's enforcement proceedings. Every day of delay increases the risk that KMH's Cyprus assets, including