Contract analysis

I. PURPOSE AND OVERVIEW This memorandum has been prepared by Calderwood & Harkness LLP ("C&H") for the exclusive use of Mr. Alexandros Stavridis in connection with his upcoming deposition in the matter of Northwind Maritime Corporation v. Thalassa Shipping & Logistics SA and Aegean Fortuna Shipholding Ltd., Index No. 655421/2023 (Sup. Ct. N.Y. Cnty., Commercial Division). This document is protected by the attorney-cl

II. GENERAL DEPOSITION GUIDELINES The following guidelines are critical to the success of this deposition. Mr. Stavridis should internalize these principles and apply them consistently throughout his testimony. A deposition is not a conversation — it is a formal legal proceeding under oath, and every word spoken by the witness becomes part of the evidentiary record that can be used at trial, on summary judgment motio

III. BACKGROUND ON THE LITIGATION A. Case Summary Northwind Maritime Corporation ("Northwind"), a marshall Islands corporation with its principal place of business in Stamford, Connecticut, filed this action on October 2, 2023, in the Supreme Court of the State of New York, New York County, Commercial Division. The case has been assigned to Part 49, before the Honorable Lorraine K. Chen, Justice of the Supreme Court.

IV. ANTICIPATED AREAS OF EXAMINATION The following sections identify the principal topics we expect opposing counsel to explore during the deposition, together with our assessment of the key facts, documents, and vulnerabilities associated with each topic. For each area, we provide specific guidance on how Mr. Stavridis should approach the anticipated questions. This guidance reflects our strategic assessment of the

I. TSL's Financial Condition and Insurance Opposing counsel may probe TSL's financial condition, insurance arrangements, and lending relationships for several purposes: to assess TSL's ability to satisfy a potential judgment, to evaluate settlement leverage, and to establish facts relevant to damages arguments. The basic facts of TSL's financial condition are as follows. For fiscal year 2022, TSL reported revenues of