Contract analysis

1. Discontinuance of All Claims With Prejudice. The parties hereby stipulate and agree that all claims asserted by Plaintiff Northwind Maritime Corporation against Defendants Thalassa Shipping & Logistics SA and Aegean Fortuna Shipholding Ltd. in the above-captioned action, including but not limited to each and every cause of action set forth in the Complaint filed on October 2, 2023, and any and all amendments there

2. Discontinuance of All Counterclaims With Prejudice. The parties hereby stipulate and agree that all counterclaims asserted by Defendants Thalassa Shipping & Logistics SA and Aegean Fortuna Shipholding Ltd. against Plaintiff Northwind Maritime Corporation in their Verified Answer and Counterclaim filed on November 17, 2023, including but not limited to the counterclaim for One Million Six Hundred Twenty Thousand Do

3. Withdrawal of All Pending Motions With Prejudice. All pending motions in this action are hereby withdrawn with prejudice, including but not limited to Defendants' Motion for Partial Summary Judgment (Motion Seq. No. 003), which was filed on September 20, 2024. The parties acknowledge that Defendants' Motion for Partial Summary Judgment was previously withdrawn by stipulation so-ordered by this Court on November 25

4. No Admission of Liability. This Stipulation of discontinuance With Prejudice does not constitute, and shall not be construed or interpreted as, an admission of liability, fault, wrongdoing, or the validity or invalidity of any claim, counterclaim, defense, or legal position by any party. The parties expressly deny any and all liability with respect to the claims and counterclaims asserted in this action. The disco

5. Retention of Jurisdiction. The parties acknowledge and agree that, contemporaneously with the execution and filing of this Stipulation of discontinuance, they have submitted to this Court a separately filed Stipulation and Order Retaining Jurisdiction to Enforce Settlement, dated November 26, 2024, which provides, among other things, that this Court shall retain jurisdiction for a period of one hundred eighty (180

6. Effective Date of discontinuance. This Stipulation of discontinuance With Prejudice shall be filed with the Clerk of the Court, County of New York, and shall be effective upon the filing of a so-ordered version endorsed by the Court. Pursuant to Section 11.2 of the Settlement Agreement, this Stipulation is to be executed and filed within ten (10) business days of Defendants' final settlement payment, designated as

7. Compliance with CPLR. This Stipulation of discontinuance is made and filed pursuant to Section 3217(a)(2) of the New York Civil Practice Law and Rules ("CPLR"), which permits the voluntary discontinuance of an action by the filing of a stipulation signed by the attorneys of record for all parties who have appeared in the action. To the extent the Court endorses this Stipulation with a so-ordered endorsement, this

8. Authority. Each signatory to this Stipulation represents and warrants that he or she is duly authorized to execute this Stipulation on behalf of his or her respective client and that such client has consented to the entry of this Stipulation and the discontinuance of all claims and counterclaims with prejudice on the terms set forth herein. Specifically, counsel for Plaintiff, Margaret Delacroix of Hargrove, Delac