Contract analysis

From: Victoria Chambers <vchambers@calderwoodharkness.com> To: Howard Quinn <hquinn@calderwoodharkness.com> Date: Fri, 30 Sep 2022 04:17:00 -0000 Subject: 1044-00007 — Thalassa FCPA — Dormant Status

Just transmitted the hold-status letter to Dimitra Karavelis-Stavrou, so the Thalassa FCPA matter (1044-00007) is officially dormant as of today. As discussed, this is coming from Nikolaos Karavelis — he wants to pause external legal spend while the family sorts out internal budget priorities, and of course the document production we've been waiting on remains outstanding. Frustrating, but it is what it is. A few hou

1. **TIME ENTRIES.** Everyone please make sure your time through today (September 30) is entered and submitted. Howard — can you confirm current WIP when you get a chance? My rough tally had us at approximately $87,500 through August 31. With the September work on the interim status memorandum and the hold-status letter, I'd estimate we should be in the $105,000–$110,000 range through today, but I want to make sure w

2. **FILE ORGANIZATION.** Jasmine, when you have a moment next week, please organize the matter folder into the following sub-folder structure:

- 01_Engagement - 02_Correspondence - 03_Client_Productions - 04_C&H_Memoranda - 05_Research - 06_Goldenshore_Agency_Agreement - 07_Financial_Analysis - 08_Compliance_Program - 09_Local_Counsel - 10_Northpoint (placeholder)

I want everything in good order so that if and when we reactivate, nobody has to spend billable time reconstructing what we had.

3. **NORTHPOINT.** I spoke with Sandra Bellingham at Northpoint Forensic Advisors yesterday. She understands the activation is on hold. They're keeping our team on soft reserve, which is the best we could ask for. If we reactivate, Sandra estimates a two-week mobilization period to get their people spun up, which is reasonable.

4. **DOSSOU & MENSAH.** Liam — we had those preliminary conversations with Amadou Dossou at Dossou & Mensah Avocats in Abidjan regarding Ivorian data-privacy issues under Loi n° 2013-450 and the employment-law questions around potential witness interviews. We never formally retained them, but the substance of those calls should be memorialized. Can you put together a brief memo summarizing what was discussed and drop

5. **CONCERNS — FOR THE FILE.** I want to flag, again, my concern about TSL's continued payment of the expediting fees to Goldenshore Maritime Consultants while this matter sits dormant. I made this point clearly in the interim status memorandum on September 12 and again in the hold-status letter I sent today. I'll say it plainly here as well: if Thalassa West Africa continues making these payments to Goldenshore and

6. **CALENDAR.** I'm setting a 60-day tickler to follow up with Dimitra. Target date is November 30, 2022. If we haven't heard anything from the client by then, I'll send her a brief status-check email to see where things stand.

I know this is a disappointing outcome — you all did really good work standing this review up quickly, and the analysis on the Goldenshore agency agreement and the port-facilitation payments was sharp. Hopefully Dimitra prevails internally and the client re-engages sooner rather than later. In the meantime, thank you for getting everything wrapped up cleanly.

Victoria Chambers Partner | White Collar & Investigations Calderwood & Harkness LLP 600 Lexington Avenue, 38th Floor New York, NY 10022 vchambers@calderwoodharkness.com +1 (212) 555-0147