Contract analysis

1. Communications between TSL personnel and Calderwood & Harkness LLP. Communications between TSL's senior management and operational personnel — including Alexandros Stavridis (Managing Director), Markos Theodorakis (Director of Chartering), Elena Papadimitriou (Director of Technical Operations), Captain Nikolaos Giannopoulos (Master, M/V Aegean Fortuna), and Petros Vlahos (Chief Engineer, M/V Aegean Fortuna) — and

2. Communications between TSL and Konstantinou & Rizos Law Offices. Communications between TSL personnel and Dimitrios Konstantinou of Konstantinou & Rizos Law Offices (Piraeus, Greece) regarding Greek corporate governance matters, regulatory compliance, GDPR considerations, and related legal advice in connection with this action.

3. Communications between TSL and/or its counsel and Oceanus Mutual Protection & Indemnity Club. Communications between TSL personnel and/or Calderwood & Harkness LLP and David Okafor of Oceanus Mutual Protection & Indemnity Club relating to P&I coverage, claims notifications, claims management, and defense of claims arising from the three incidents, made in anticipation of litigation and/or at the direction of couns

4. Internal Calderwood & Harkness LLP memoranda and work product. Internal memoranda, research, analyses, strategy documents, and other work product prepared by attorneys and staff at Calderwood & Harkness LLP relating to legal strategy, factual investigation, case assessment, expert retention, and litigation preparation in this matter.

5. Communications between counsel and retained experts. Communications between Calderwood & Harkness LLP and experts retained in anticipation of litigation, including Dr. Henrik Sørensen of Nordic Maritime Consulting Group ApS (Copenhagen, Denmark), a maritime engineering expert retained to provide opinions on the cause of the three mechanical failures at issue, and Dr. Constance Albright of Clearwater Economics LLC,