Contract analysis

I. BACKGROUND A. Identity of the Client and Engagement This letter is written on behalf of our client, Thalassa Shipping & Logistics Société Anonyme ("TSL"), a Greek société anonyme (anonimi etairia, or A.E.) incorporated in Piraeus, Greece, and registered with the Piraeus Commercial Registry under number 78214/06/B/09/42. TSL maintains its headquarters at 47 Akti Miaouli, 185 35 Piraeus, Greece. TSL's Economic Opera

II. INDEMNIFICATION CLAIM A. Contractual Basis — CBA Article 9.1

Article 9.1 of the CBA contains the following indemnification provision: "The Broker shall indemnify and hold harmless the Client against any losses, damages, penalties, interest, costs, and expenses (including reasonable attorneys' fees) arising from or attributable to the Broker's negligent or erroneous performance of customs clearance services, including but not limited to errors in tariff classification, customs

1. Peloros selected the CN classification codes. TSL provided Peloros with detailed equipment specifications, purchase documentation, manufacturer's technical data sheets, operating manuals, and related commercial information for all of the imported marine cargo-handling equipment. On the basis of this information, Peloros — acting through you as the designated licensed customs broker — exercised its professional jud

2. The subheading CN 8426 41 00 ("on tyres") is facially incorrect for rail-mounted equipment. Irrespective of the heading-level dispute between heading 8426 and heading 8428 — a question on which reasonable professionals might differ — the subheading selected by Peloros is facially and unambiguously wrong. CN code 8426 41 00 covers "Self-propelled [machinery], on tyres." Both the twelve STS Gantry Cranes and the eig

3. Professional obligations under Greek law. Peloros's professional obligations as a licensed customs broker are governed by Presidential Decree 67/2000, which establishes the regulatory framework for customs broker licensing and professional conduct in Greece. Under Presidential Decree 67/2000, a licensed customs broker is required to exercise professional diligence (επιμέλεια επαγγελματία) in the selection of tarif

III. DOCUMENT PRESERVATION DEMAND A. Preservation Instruction TSL hereby demands that Peloros immediately preserve and refrain from destroying, altering, discarding, overwriting, or otherwise disposing of all documents and records in its possession, custody, or control relating to the forty-seven (47) customs entries filed on behalf of TSL between March 2019 and January 2022, as well as all documents and records rela

1. All forty-seven (47) Single Administrative Documents (SADs) filed with AADE on TSL's behalf, together with all supporting documentation submitted in connection with such filings, including but not limited to commercial invoices, packing lists, bills of lading, certificates of origin, insurance certificates, inspection reports, and any annexes or attachments thereto.

2. Peloros's internal working files and classification analysis records for each customs entry, including any tariff classification worksheets, CN code lookup results, classification decision trees, internal review notes, supervisory checklists, and any other documentation reflecting the analytical process by which the CN codes were selected.

3. All correspondence between Peloros and TSL regarding the classification and valuation of the imported equipment, including emails, letters, facsimile transmissions, records of telephone calls, meeting notes, and any other written or electronic communications.

4. All correspondence between Peloros and AADE regarding the customs entries filed on TSL's behalf, including any written or electronic communications with customs officials, responses to queries, requests for additional information, and any other regulatory correspondence.

5. Classification reference materials, tariff databases, Combined Nomenclature publications, Explanatory Notes to the Harmonized System or the Combined Nomenclature, WCO classification opinions, EU Classification Regulations, AADE circulars, or internal guidance documents consulted by Peloros or its personnel in selecting the CN codes for the TSL entries.

6. Time records, billing records, fee calculations, invoices, payment records, and engagement files for the TSL account, including any records reflecting the scope of work performed by Peloros in connection with each customs entry.

7. Any internal memoranda, notes, analyses, opinions, or communications among Peloros personnel — including emails, instant messages, and other electronic communications — regarding the TSL customs entries, the classification of marine cargo-handling equipment generally, the selection of CN code 8426 41 00, or the distinction between tyre-mounted and rail-mounted equipment for classification purposes.

8. Peloros's professional indemnity insurance policy documents, including current and historical policy wordings, declarations pages, endorsements, coverage limits, retention and deductible amounts, notice-of-claim provisions, and any correspondence with Peloros's insurance broker or agent regarding coverage for claims of the type described in this letter. C. Format Scope The preservation obligation extends to all do

IV. REQUEST FOR INFORMATION TSL requests that Peloros provide the following information within twenty (20) business days of the date of this letter (i.e., by no later than January 16, 2023):

1. Preservation hold confirmation. Written confirmation, signed by an authorized representative of Peloros, that Peloros has implemented a document preservation hold covering all categories of documents described in Section III above, and that all relevant Peloros personnel have been instructed in writing to preserve such documents and to suspend any automated deletion, overwriting, or destruction processes that coul

2. Professional indemnity insurance details. The identity and contact information of Peloros's professional indemnity insurer, including the following: (a) The name, address, and contact information of the insurer; (b) The policy number; (c) The policy period (inception and expiration dates); (d) The coverage limits, stated on both a per-claim and aggregate basis; (e) The applicable retention or deductible amount; (f

3. Responsible personnel identification. A statement identifying, by name and title, the Peloros personnel who were responsible for selecting the Combined Nomenclature classification codes for the forty-seven customs entries filed on TSL's behalf, including any personnel who participated in a supervisory or quality review process for the classification selections. TSL requests that Peloros describe the internal revie

V. RESERVATION OF RIGHTS A. Comprehensive Rights Reservation This letter constitutes formal notice of TSL's potential indemnification claim against Peloros under the CBA and applicable Greek law. TSL expressly reserves all rights, claims, and remedies against Peloros, whether arising under contract, statute, regulation, or in tort, including without limitation:

1. Contractual indemnification under Article 9.1 of the CBA, as described in Section II above, including the right to recover all additional duties, penalties, interest, VAT adjustments, defense costs, expert fees, and related expenses arising from Peloros's erroneous classification and valuation of the imported equipment.

2. Statutory liability under Presidential Decree 67/2000 governing customs broker licensing and professional obligations in Greece, which provides that a licensed customs broker is responsible for the accuracy of customs declarations filed on behalf of a client and may be held jointly and severally liable (εις ολόκληρον ευθύνη) with the importer for additional duties, penalties, and interest arising from errors in cu

3. Tortious liability for professional negligence under Articles 914 and 330 of the Greek Civil Code (Αστικός Κώδικας), to the extent that Peloros's errors constitute a failure to exercise the degree of care and diligence required of a reasonably competent licensed customs broker, resulting in quantifiable damage to TSL. B. Non-Waiver. This letter is not, and shall not be construed as, a waiver of any right, claim, r

VI. CLOSING TSL expects Peloros's full and prompt cooperation in preserving all relevant records and providing the requested information within the timeframe specified in Section IV above. Failure to preserve documents in accordance with the demand set forth in Section III may result in adverse inferences in any subsequent proceedings and may give rise to additional claims against Peloros. Please direct all responses