Contract analysis

1. INTRODUCTION AND PURPOSE This cover memorandum accompanies the supporting documentation package assembled by Calderwood & Harkness LLP ("C&H") for the application for recognition and enforcement of LCIA Award No. 224718 (the "Award") before the Dubai Court of First Instance (Case No. 1893/2024), filed on behalf of Thalassa Shipping & Logistics SA ("TSL" or the "Applicant") against Korinthian Maritime Holdings Ltd.

1. To serve as a master index and description of all documents included in the supporting documentation package, organized by numbered Tab references (Tabs A through L), with a full description of the nature, provenance, and relevance of each document;

2. To confirm the authentication, legalization, and translation status of each document in the package, demonstrating that all documents have been properly certified, apostilled, legalized by the Embassy of the United Arab Emirates, and translated into Arabic by certified legal translators, in compliance with UAE court filing requirements; and

3. To provide guidance to our instructed UAE counsel, Al-Rashid Hatem & Associates ("ARH"), on the assembly, presentation, and filing of these materials before the Dubai Court of First Instance, including instructions regarding the concurrent precautionary attachment application. In addition to the enforcement application itself, the documentation package supports a concurrent application for precautionary attachment

2. PARTIES TO THE ENFORCEMENT APPLICATION 2.1 Applicant / Award Creditor Thalassa Shipping & Logistics SA was founded in 1987 by the Papadimitriou family and is one of the leading independent shipping and logistics operators in the Eastern Mediterranean and wider international markets. TSL operates a diversified fleet of thirty-four (34) vessels, comprising bulk carriers, product and crude oil tankers, and container

3. SUMMARY OF THE ARBITRAL AWARD 3.1 Arbitral Institution and Procedural Framework The arbitration arose out of three related time charter-party agreements entered into between TSL (as charterer) and KMH (as disponent owner) in respect of the vessels M/V Aegean Fortuna (IMO 9784521), M/V Crimson Horizon (IMO 9801334), and M/V Volga Spirit (IMO 9756892). Each charter-party contained an arbitration clause (Clause 45 in

4. INDEX OF SUPPORTING DOCUMENTS The supporting documentation package comprises twelve (12) Tabs, designated Tab A through Tab L. Each Tab is described in detail below, including a description of the document, its original language, its authentication and legalization status, and the availability of a certified Arabic translation. 4.1 Tab A — Certified Copy of LCIA Award No. 224718 Description: Complete certified cop

5. AUTHENTICATION AND LEGALIZATION PROCESS The authentication and legalization of documents included in this package has been carried out in accordance with the requirements of UAE law and international conventions applicable to the submission of foreign documents before UAE courts. The process applied to each category of document is described below. 5.1 Documents Originating in England and Wales All documents origin

6. CHECKLIST OF DOCUMENT STATUS The following table summarises the status of each Tab in the supporting documentation package as of the date of this memorandum (22 August 2024): Confirmation: As of the date of this memorandum (22 August 2024), all documents listed above are confirmed as complete and ready for filing with the Dubai Court of First Instance. Four (4) copies of each document have been prepared — one orig

7. FILING INSTRUCTIONS TO AL-RASHID HATEM & ASSOCIATES Calderwood & Harkness LLP respectfully requests that Al-Rashid Hatem & Associates proceed as follows with respect to the filing and prosecution of the enforcement application and precautionary attachment application: 7.1 Simultaneous Filing ARH is instructed to file the enforcement application and the precautionary attachment application simultaneously on 22 Augu

8. PARALLEL PROCEEDINGS — SUMMARY FOR UAE COURT'S INFORMATION In accordance with principles of comity and the procedural requirements applicable to multi-jurisdictional enforcement proceedings, the following summary of parallel enforcement proceedings is provided for disclosure to the Dubai Court of First Instance. TSL is pursuing enforcement of the Award in multiple jurisdictions concurrently in order to maximize th

9. CONTACT DETAILS AND DISTRIBUTION 9.1 Calderwood & Harkness LLP (Applicant's Lead Counsel — England) 9.2 Al-Rashid Hatem & Associates (Applicant's UAE Counsel) 9.3 Client Contact 9.4 Distribution of This Memorandum and Documentation Package The original supporting documentation package, together with this cover memorandum, has been delivered to Al-Rashid Hatem & Associates by secure international courier (tracking

10. SIGNATURE BLOCK This Cover Memorandum and Index of Supporting Documentation has been prepared, reviewed, and approved as set forth below. Prepared by: ________________________________________ Patrick Gallagher Working Associate Calderwood & Harkness LLP 45 Moorgate, London EC2R 6AR Date: 22 August 2024 Reviewed by: ________________________________________ Hannah Brinkley Lead Associate Calderwood & Harkness LLP 4