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CALDERWOOD & HARKNESS LLP Solicitors & International Arbitration Counsel 45 Moorgate London EC2R 6AR United Kingdom

Tel: +44 (0)20 7946 8200

Fax: +44 (0)20 7946 8201

www.calderwoodharkness.com

3 October 2024

PRIVILEGED AND CONFIDENTIAL — FOR THE ATTENTION OF ADDRESSEE ONLY

Nadia Makrides Partner, Litigation & Enforcement Kyprianos Makrides & Partners 15 Grivas Digenis Avenue Nicosia 1066 Cyprus

Re: Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd. — Nicosia District Court, Case No. 2247/2024 — Execution Against Shares of Oceangate Ventures Ltd. (Reg. No. HE 401293)

Our Ref: SE/HB/PG/TSL-Enf-CY

LCIA Ref: No. 224718

Dear Ms. Makrides,

Opening

We write in our capacity as lead enforcement counsel for Thalassa Shipping & Logistics SA ("TSL" or the "Client") in connection with the above-referenced matter. This letter is authored by Hannah Brinkley, Lead Associate, under the supervision of Samuel Eklund, Responsible Partner, at Calderwood & Harkness LLP ("C&H"). The purpose of this letter is to set out detailed instructions to Kyprianos Makrides & Partners ("KM&P") regarding the procedure for the forced sale of the entire shareholding of Korinthian Maritime Holdings Ltd. ("KMH") in Oceangate Ventures Ltd. ("Oceangate"), following the enforcement order granted by the Nicosia District Court on 30 September 2024 in Case No. 2247/2024.

As you are aware, the enforcement order in question was obtained to recognize and enforce LCIA Award No. 224718, dated 28 June 2024 (the "Award"), which was rendered in favour of TSL by a three-member tribunal seated in London. The Award was made in the total amount of £96,450,000 on the substantive claims, together with £12,150,000 in respect of the tribunal's costs award, yielding a total principal sum of £108,600,000 (the "Award Debt"). Post-award interest accrues on the full Award Debt at the rate of 5.25% per annum simple, calculated from 29 June 2024 until the date of full satisfaction of the Award.

The enforcement order was obtained by KM&P under the provisions of the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958), as implemented in the domestic law of the Republic of Cyprus through the International Commercial Arbitration Law (Law 101/1987) and the relevant provisions of the Arbitration Law, Cap. 4. We understand that the enforcement order was granted on an ex parte basis and is now operative. We further understand that no application to set aside the enforcement order has been filed by KMH or its legal advisers as at the date of this letter.

We also draw your attention to the freezing injunction that was granted on 12 August 2024 by the Nicosia District Court (the "Cyprus Freezing Injunction"), which operates over KMH's shareholding in Oceangate and over KMH's bank accounts maintained in Cyprus. The Cyprus Freezing Injunction, together with the worldwide freezing order previously granted in England on 16 July 2024 by Mr. Justice Ashworth of the Commercial Court (Claim No. CL-2024-000487), has been instrumental in preserving the target assets pending enforcement. We are now in a position to move to the execution phase, and we set out our instructions in detail below.

1. Background on Oceangate Ventures Ltd. and Target Assets

For the purposes of completeness, and to ensure that all relevant information is reflected in the forthcoming court applications, we set out the background to the target assets as follows.

1.1 Oceangate Ventures Ltd. is a private limited liability company incorporated in the Republic of Cyprus under Registration No. HE 401293. Its registered office is at 28 Themistokli Dervi Avenue, Suite 604, Nicosia 1066, Cyprus. Oceangate was incorporated on or about 14 March 2019 and remains active on the Cyprus Registrar of Companies register.

1.2 KMH, itself a company incorporated in the Republic of Cyprus under Registration No. HE 387421, with its registered office at 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus, holds 100% of the issued share capital of Oceangate. Based on the information available to us, the issued share capital of Oceangate comprises 10,000 ordinary shares of €1.00 nominal value each, all of which are registered in the name of KMH. There are no minority shareholders, and no other classes of shares have been issued.

1.3 Oceangate serves as an intermediate holding company within the broader corporate structure controlled by KMH. Specifically, Oceangate is the sole shareholder of Dnepr Shipholding Inc., a company incorporated in the British Virgin Islands under Company No. 2014876 ("Dnepr Shipholding"). Dnepr Shipholding is, in turn, the registered owner of the following vessels:

(a) M/V Aegean Fortuna (IMO No. 9784521), a Supramax Bulk Carrier of 58,200 DWT, registered under the flag of the Republic of the marshall Islands; and

(b) M/V Volga Spirit (IMO No. 9756892), a Panamax Bulk Carrier of 76,400 DWT, registered under the flag of the Republic of Cyprus.

1.4 The foregoing shareholding and vessel ownership structure has been confirmed through the independent asset tracing investigations conducted on behalf of TSL by Hartwell Pemberton LLP, specialist corporate intelligence and asset tracing consultants. Hartwell Pemberton produced a preliminary asset tracing report dated 15 August 2024, and an updated report incorporating further findings dated 1 October 2024. An extract of the updated report confirming the Oceangate corporate structure is enclosed with this letter for ease of reference and for use in the court proceedings.

1.5 The Oceangate shareholding constitutes a significant and valuable component of KMH's identifiable assets within the jurisdiction of the Republic of Cyprus. Given the value of the two vessels held through Dnepr Shipholding — which, based on Northcape Maritime Advisory Ltd.'s most recent desktop valuations, are collectively estimated at approximately US$42,000,000 to US$47,000,000 — the Oceangate shares represent the primary target for execution in Cyprus. Additional value may be attributable to Oceangate's cash balances and receivables, though we understand from the Hartwell Pemberton reports that the majority of the entity's value derives from its indirect vessel ownership.

1.6 For completeness, we note that KMH is ultimately beneficially owned by the Volkov family through a combination of BVI and Cypriot holding structures. Mr. Andrei Volkov is the ultimate beneficial owner ("UBO") and de facto director of the KMH group, exercising effective control over its operations and financial affairs. Mr. Sergei Volkov, Andrei Volkov's brother, serves as a named director of both KMH and Oceangate. This information is relevant to the history of asset dissipation that has been documented in these proceedings and in the English Commercial Court proceedings, as further discussed below.

2. Instructions for Initiating Forced Sale Proceedings

We instruct KM&P as follows in connection with the initiation of the forced sale process.

2.1 KM&P is instructed to apply immediately — and in any event within five (5) business days of the date of this letter — to the Nicosia District Court for an order for execution by forced sale of KMH's entire 100% shareholding in Oceangate Ventures Ltd. (being 10,000 ordinary shares of €1.00 nominal value each), pursuant to and in satisfaction of the enforcement order dated 30 September 2024 in Case No. 2247/2024 (the "Execution Application").

2.2 The Execution Application should clearly reference Case No. 2247/2024, the enforcement order of 30 September 2024, and the underlying LCIA Award No. 224718 dated 28 June 2024. Certified copies of both the enforcement order and the Award should be attached to the Execution Application as exhibits. We enclose certified copies of both documents with this letter for that purpose. If additional certifications, apostilles, or certified translations into Greek are required by the court, please arrange for these to be prepared as a matter of urgency and notify us of any associated costs.

2.3 We request that KM&P coordinate directly with the Cyprus court bailiff (the Dikastikos Epidotis) to initiate the execution process in accordance with the applicable provisions of the Civil Procedure Law of Cyprus (Cap. 6) and the Civil Procedure Rules. KM&P should take all necessary procedural steps to ensure that the bailiff is properly instructed and equipped with the required documentation to proceed with the seizure and sale of the shares.

2.4 The Execution Application should specify that the judgment debt in respect of which execution is sought is the full amount of the enforcement order — namely, £108,600,000 in principal, together with post-award interest at 5.25% per annum simple accruing from 29 June 2024 until the date of full satisfaction. However, KM&P should note that the judgment debt is subject to credit for amounts recovered in other jurisdictions. As at the date of this letter, the following partial recovery has been made:

(a) The sum of £18,720,000 has been recovered in England by way of a final third-party debt order made against Meridian Trust Bank Ltd., dated 3 September 2024, in the English Commercial Court proceedings (Claim No. CL-2024-000487). This amount has been received into TSL's solicitors' client account and credited against the Award Debt.

2.5 Accordingly, the outstanding balance of the Award Debt is approximately £89,880,000 in principal (before interest), plus accrued post-award interest. TSL reserves the right to update the outstanding balance at any time to reflect further recoveries in other jurisdictions. We will communicate promptly any additional recoveries made in the parallel enforcement proceedings in Singapore (Originating Summons No. 872/2024), the United Arab Emirates (Case No. 1893/2024, ADGM Courts), or elsewhere, so that the execution in Cyprus can proceed on the basis of accurate figures and to avoid any risk of double recovery.

2.6 Please revert at your earliest convenience with a detailed procedural timeline for the execution process, including: (i) the anticipated date for filing the Execution Application; (ii) the expected timeframe for the court's direction on the manner of execution; (iii) the advertisement requirements and their anticipated duration; and (iv) the projected date for the forced sale itself. An indicative timeline will assist TSL and C&H in coordinating the multi-jurisdictional enforcement strategy.

3. Valuation Requirements

3.1 We anticipate that the Nicosia District Court will require, or at minimum expect, an independent valuation of the Oceangate shares prior to ordering their sale, in order to establish a reserve price or to guide the forced sale process and ensure that the shares are not sold at an undervalue. We instruct KM&P to take all necessary steps to arrange for such a valuation on an expedited basis.

3.2 The valuation must take into account the nature of Oceangate as an intermediate holding company whose principal asset is its 100% shareholding in Dnepr Shipholding Inc. (BVI). The value of the Oceangate shares is therefore substantially determined by the value of Dnepr Shipholding's underlying assets, principally the two vessels, M/V Aegean Fortuna and M/V Volga Spirit, as well as any charter receivables, cash balances, and other assets or liabilities at the Dnepr Shipholding and Oceangate levels. The valuation should also address the existence of any encumbrances on the shares or on the vessels, including any ship mortgages or security interests that may be in place.

3.3 We note that Northcape Maritime Advisory Ltd. ("Northcape"), located at 3 Thomas More Square, London E1W 1WY, has previously provided vessel valuations in this matter. Should the Cyprus court require or accept a vessel-level valuation to underpin the share valuation, C&H is in a position to coordinate directly with Captain Ian Forsyth, Senior Valuation Surveyor at Northcape, to commission updated market value appraisals of both M/V Aegean Fortuna and M/V Volga Spirit. We would expect such updated valuations to be available within seven (7) to ten (10) business days of instruction.

3.4 If, however, the Nicosia District Court requires or prefers a valuation to be carried out by a Cyprus-based or Cyprus-registered valuation expert — whether for reasons of procedural formality, judicial preference, or local practice — we request that KM&P recommend a suitable expert. Please provide us with: (i) the name and credentials of the proposed valuer; (ii) the valuer's relevant experience in valuing corporate shareholdings and/or shipping assets; (iii) an estimated timeline for completion of the valuation; and (iv) a fee estimate for the engagement. C&H will review the recommendation promptly and provide approval or further direction.

3.5 We cannot overstate the importance of expedition in the valuation process. KMH has demonstrated a well-documented pattern of post-award asset dissipation, as evidenced by the findings in Hartwell Pemberton's reports and as recorded in the judgment of Mr. Justice Ashworth of 16 July 2024 granting the worldwide freezing order in the English proceedings. Among other things, the evidence before the English court disclosed that, within days of the Award being issued, KMH procured the transfer of approximately US$8,400,000 from Dnepr Shipholding's operating account at Tyche Bank (Cyprus) to an account held at a bank in Ras Al Khaimah in the name of a newly incorporated RAK ICC entity, Blacksea Trading & Logistics FZE, which appears to be controlled by Mr. Andrei Volkov. Any delay in completing the valuation and proceeding to the forced sale creates a risk that further steps will be taken to diminish the value of the assets, whether through the dissipation of charter revenues, the creation of spurious encumbrances, or other means.

4. Coordination with Court Bailiff and Sale Mechanism

We set out below detailed instructions for the practical steps involved in coordinating with the Cyprus court bailiff and effecting the forced sale.

4.1 Filing of the Execution Writ. KM&P should file the appropriate execution writ (or application for a warrant of execution, as the procedural form may require) with the Nicosia District Court, referencing the enforcement order in Case No. 2247/2024 and the Award. The execution writ should identify the specific property to be seized — namely, 10,000 ordinary shares of €1.00 nominal value each in Oceangate Ventures Ltd. (HE 401293), constituting 100% of the issued share capital, registered in the name of KMH.

4.2 Service of the Execution Writ. The execution writ should be served on:

(a) KMH, at its registered office at 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus; and

(b) Oceangate Ventures Ltd., at its registered office at 28 Themistokli Dervi Avenue, Suite 604, Nicosia 1066, Cyprus.

We note that both entities share the same building, and we anticipate that service can be effected simultaneously. If there are any difficulties in effecting service — for instance, if the registered offices are found to be vacant or if service is refused — please notify us immediately so that we may consider substituted service or other procedural options.

4.3 Notation on the Registrar of Companies Records. We instruct KM&P to ensure that the execution is formally noted on the records of the Cyprus Registrar of Companies in respect of Oceangate Ventures Ltd. (HE 401293). This notation is essential to prevent KMH or any person acting on its behalf from transferring, encumbering, or otherwise dealing with the Oceangate shares pending completion of the forced sale. Please confirm whether such notation can be effected by the court bailiff directly, or whether a separate application or notification to the Registrar is required. In either case, this step should be taken at the earliest possible opportunity.

4.4 Advertisement of the Forced Sale. The forced sale must be advertised in accordance with the requirements of Cypriot procedural law. We understand that this typically involves publication in the Official Gazette of the Republic of Cyprus (Episimi Efimerida tis Dimokratias) and in one or more local newspapers of general circulation. Please confirm the precise advertisement requirements, including: (i) the number of publications required; (ii) the mandatory notice period between publication and the date of sale; (iii) the form and content of the advertisement; and (iv) the estimated cost of publication. If there is any discretion as to the choice of newspaper, please select the publication most likely to reach potential purchasers of a shareholding in a shipping holding company.

4.5 Conduct of the Sale. We understand that under Cypriot law, the forced sale of shares may be conducted by public auction. If, however, the court permits a sale by private treaty — for instance, where the court is satisfied that a private sale would achieve a better price or a more efficient outcome — we would wish to explore that option. In the case of a public auction, we request that KM&P provide details of the auction process, including the venue, date, reserve price (as established by the independent valuation), and any conditions of sale. In the case of a private treaty sale, the sale price should in no event be less than the independently assessed fair market value of the shares, and any proposed purchaser should be vetted for financial capacity and absence of connections to KMH or the Volkov family.

4.6 Post-Sale Transfer. We request that KM&P confirm whether any consent or notification to the Registrar of Companies is required to transfer the Oceangate shares to the purchaser following the forced sale, and to take all necessary steps to ensure a clean and effective transfer. This includes arranging for the issuance of new share certificates in the name of the purchaser, updating the register of members of Oceangate, and filing any required returns with the Registrar. We need to ensure that the purchaser obtains unencumbered title to the shares free and clear of any claims by KMH, the Volkov family, or any third party.

4.7 Opposition by KMH. We are aware that KMH is represented in Cyprus by Vassiliadis & Economou LLC, located at 7 Stasinou Avenue, 3rd Floor, Nicosia 1060. The partners with conduct of the matter on behalf of KMH are Mr. Georgios Vassiliadis and Ms. Eleni Economou. We consider it likely that KMH and/or its counsel will seek to oppose or delay the forced sale, whether by challenging the enforcement order, seeking a stay of execution, or raising procedural objections. We instruct KM&P to vigorously resist any such application and to defend TSL's right to proceed with execution. In the event that any opposition is filed or threatened, please report the matter to C&H immediately, providing copies of all relevant filings and submissions, so that we may provide support and, if necessary, coordinate with our English proceedings team.

5. KMH Bank Accounts in Cyprus

5.1 In addition to the forced sale of Oceangate shares, KM&P is instructed to simultaneously pursue execution against KMH's Cyprus bank accounts that are subject to the Cyprus Freezing Injunction granted on 12 August 2024. We understand from the freezing injunction proceedings and from KMH's disclosure that the following accounts are held to KMH's credit in Cyprus:

(a) Account No. [details held on file] at Hellenic Commercial Bank Ltd., Nicosia Main Branch;

(b) Account No. [details held on file] at Tyche Bank (Cyprus) Ltd., Limassol Branch; and

5.2 KM&P is instructed to apply for garnishment or attachment orders over all funds held to KMH's credit in the foregoing accounts, and in any other accounts that may be identified, to the extent that such funds are not already subject to an existing garnishment or execution order. The applications should be made promptly and in parallel with the Execution Application for the forced sale of the Oceangate shares.

5.3 All proceeds recovered from the garnishment of KMH's bank accounts should be remitted to TSL together with the proceeds of the share sale, as set out in Section 6 below.

6. Remittance of Proceeds

6.1 All proceeds from the forced sale of the Oceangate Ventures shares and from the garnishment of KMH's Cyprus bank accounts are to be remitted to TSL's designated recovery account. The relevant bank details are as follows:

Account Holder: Thalassa Shipping & Logistics SA

Bank: Ionian National Bank SA

Bank Address: 22 Stadiou Street, Athens 105 64, Greece

Account Number and IBAN: To be provided separately via secure communication.

6.2 C&H will send full wire transfer instructions under separate cover, transmitted via secure encrypted communication, or will confirm that the wire instructions previously provided to KM&P in connection with the freezing injunction proceedings remain current and valid. KM&P should not effect any remittance until written confirmation of the correct wire instructions has been received from C&H.

6.3 We instruct KM&P to ensure that the conversion from EUR to GBP — or, if TSL's account at Ionian National Bank is denominated in EUR or is capable of receiving EUR deposits, remittance in EUR — is handled at the most favorable exchange rate available at the time of remittance. Any currency conversion costs, wire transfer fees, or bank charges should be minimized to the greatest extent possible. If KM&P is in a position to select the conversion mechanism (for example, by directing the court-appointed fund custodian to convert via a competitive FX rate), please do so in TSL's interests.

6.4 Upon remittance, we request that KM&P provide C&H and TSL with a detailed accounting, in writing, setting out: (i) the gross proceeds of the share sale; (ii) the gross proceeds of any bank account garnishment; (iii) all deductions, itemized by category, including court fees, bailiff costs and commissions, valuation fees, advertisement costs, and any other disbursements; (iv) the net proceeds available for remittance; and (v) the exchange rate applied, the date and time of conversion, and the identity of the converting institution.

6.5 For the avoidance of doubt, all professional costs and fees of KM&P in connection with the execution proceedings — including court fees, disbursements, and KM&P's own time charges — will be billed separately to C&H in accordance with the existing fee arrangements between our respective firms. We note for internal purposes that KM&P's total estimated fees for the execution phase are €285,000, and any material deviation from this estimate should be flagged to C&H in advance of the costs being incurred.

7. Reporting and Coordination

7.1 We request that KM&P provide written progress reports to C&H on a weekly basis, every Friday by close of business (Nicosia time), until the execution proceedings are completed and all proceeds have been remitted to TSL. The weekly reports should cover, at a minimum: (i) the current procedural status of the Execution Application and any related applications; (ii) any filings made or orders received during the reporting week; (iii) any communications with KMH's counsel, Vassiliadis & Economou LLC; (iv) any issues or obstacles encountered; and (v) the anticipated next steps and timeline.

7.2 All substantive correspondence with Vassiliadis & Economou LLC, whether by letter, email, or otherwise, should be copied to C&H at the following addresses:

Hannah Brinkley, Lead Associate — h.brinkley@calderwoodharkness.com

Patrick Gallagher, Working Associate — p.gallagher@calderwoodharkness.com

Calderwood & Harkness LLP, 45 Moorgate, London EC2R 6AR, United Kingdom

7.3 Any court filings, orders, directions, or judgments received in the Cyprus proceedings should be forwarded to C&H immediately upon receipt, by email in the first instance with hard copies to follow by courier where originals are required.

7.4 We draw KM&P's attention to the fact that enforcement proceedings are being pursued in parallel in multiple jurisdictions, as follows:

(a) Singapore: Originating Summons No. 872/2024, with local counsel Straits Meridian LLP. In those proceedings, TSL obtained the arrest of M/V Crimson Horizon (IMO 9812347) on 20 August 2024, and the recognition and enforcement application is proceeding before the Singapore High Court. We await a hearing date.

(b) United Arab Emirates: Case No. 1893/2024 before the Abu Dhabi Global Market Courts, with local counsel Al-Rashid Hatem & Associates. A precautionary attachment order was granted on 28 August 2024 over certain KMH-related assets located in the UAE.

(c) England: Claim No. CL-2024-000487 in the Commercial Court. The worldwide freezing order granted by Mr. Justice Ashworth on 16 July 2024 remains in full force and effect. The third-party debt order against Meridian Trust Bank Ltd. has been satisfied as noted above. Further enforcement applications in England are under consideration.

7.5 KM&P should be mindful of this multi-jurisdictional context at all times and should inform the Nicosia District Court, as appropriate and as required by the court's rules or practice, of the steps being taken in other jurisdictions to avoid any risk of over-recovery or double recovery. C&H will keep KM&P updated on developments in the other enforcement proceedings that are material to the Cyprus execution.

7.6 We further instruct KM&P to maintain detailed and accurate contemporaneous time records for all work performed in connection with these execution proceedings. TSL intends to pursue KMH for the full costs of enforcement, including the costs incurred in Cyprus, and detailed time records will be necessary to support any costs application.

8. Urgency and Timeline

8.1 We wish to emphasize in the strongest terms that time is of the essence in this matter. KMH, under the direction of Mr. Andrei Volkov, has demonstrated a persistent and deliberate pattern of asset dissipation in the period following the issuance of the Award. The evidence placed before the English Commercial Court and the Nicosia District Court in support of the respective freezing injunctions documented multiple instances of asset transfers, corporate restructuring, and the movement of funds to jurisdictions with less robust enforcement mechanisms. Every day that passes without execution creates a risk that further steps will be taken — whether through the interposition of additional corporate layers, the creation of spurious security interests, or the physical relocation of vessels — to diminish the value of the assets available to satisfy the Award Debt.

8.2 We are particularly concerned about the position of M/V Volga Spirit (IMO 9756892), one of the two vessels held through Dnepr Shipholding Inc. under the Oceangate structure. According to the most recent AIS tracking data available to us, M/V Volga Spirit was last reported at anchorage at Fujairah, United Arab Emirates. There is a risk that this vessel may be moved to a jurisdiction where enforcement is more difficult, or that arrangements may be made to sell or refinance the vessel, thereby diminishing the value of the Oceangate shares that are the subject of the forced sale. The execution of the forced sale of the Oceangate shares should therefore be completed before any further restructuring or dissipation by KMH can take effect.

8.3 We request that KM&P aim to complete the entire forced sale process — from filing the Execution Application through to receipt of sale proceeds — within a period of four (4) to six (6) weeks, if procedurally possible. We recognise that this timeline is ambitious and depends on court scheduling, advertisement requirements, and the absence of significant opposition from KMH. We therefore request that KM&P revert at the earliest opportunity with a realistic assessment of the achievable timeline, together with any recommendations for procedural steps that might expedite the process.

Closing

We trust that the foregoing instructions are clear and comprehensive. Should KM&P require any clarification or wish to discuss any aspect of these instructions, we are available for a telephone or video conference at your convenience. Please do not hesitate to contact us directly at the details below.

The relevant contact details at C&H for this matter are as follows:

Hannah Brinkley, Lead Associate Direct Line: +44 (0)20 7946 8247

Email: h.brinkley@calderwoodharkness.com

Patrick Gallagher, Working Associate Direct Line: +44 (0)20 7946 8263

Email: p.gallagher@calderwoodharkness.com

The engagement is overseen by Samuel Eklund, Responsible Partner, who may be contacted at s.eklund@calderwoodharkness.com or on +44 (0)20 7946 8210 if required.

We look forward to receiving KM&P's confirmation of receipt of these instructions and an initial assessment of the procedural timeline at the earliest opportunity.

Yours faithfully,

CALDERWOOD & HARKNESS LLP

By: ________

Hannah Brinkley Lead Associate, Litigation (General) Calderwood & Harkness LLP 45 Moorgate, London EC2R 6AR United Kingdom

cc:

Samuel Eklund, Responsible Partner, Calderwood & Harkness LLP

Patrick Gallagher, Working Associate, Calderwood & Harkness LLP

Ioanna Christodoulou, General Counsel, Thalassa Shipping & Logistics SA, 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece

Andreas Kyprianos, Senior Partner, Kyprianos Makrides & Partners

Enclosures:

1. Certified copy of the Nicosia District Court enforcement order dated 30 September 2024 (Case No. 2247/2024)

2. Certified copy of LCIA Award No. 224718 dated 28 June 2024

3. Hartwell Pemberton LLP asset tracing report excerpt re: Oceangate Ventures Ltd. corporate structure (updated report dated 1 October 2024)

4. Copy of the Cyprus freezing injunction order dated 12 August 2024

5. Wire transfer instructions for TSL's recovery account at Ionian National Bank SA (to follow under separate secure cover)

This letter and its enclosures are strictly privileged and confidential, intended solely for the use of the addressee. If you have received this communication in error, please notify the sender immediately and destroy all copies. Any unauthorised use, disclosure, or distribution is strictly prohibited.

CALDERWOOD & HARKNESS LLP Solicitors & International Arbitration Counsel 45 Moorgate London EC2R 6AR United Kingdom
Tel: +44 (0)20 7946 8200
Fax: +44 (0)20 7946 8201
www.calderwoodharkness.com
3 October 2024
PRIVILEGED AND CONFIDENTIAL — FOR THE ATTENTION OF ADDRESSEE ONLY
Nadia Makrides Partner, Litigation & Enforcement Kyprianos Makrides & Partners 15 Grivas Digenis Avenue Nicosia 1066 Cyprus
Re: Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd. — Nicosia District Court, Case No. 2247/2024 — Execution Against Shares of Oceangate Ventures Ltd. (Reg. No. HE 401293)
Our Ref: SE/HB/PG/TSL-Enf-CY
LCIA Ref: No. 224718
Dear Ms. Makrides,
Opening
We write in our capacity as lead enforcement counsel for Thalassa Shipping & Logistics SA ("TSL" or the "Client") in connection with the above-referenced matter. This letter is authored by Hannah Brinkley, Lead Associate, under the supervision of Samuel Eklund, Responsible Partner, at Calderwood & Harkness LLP ("C&H"). The purpose of this letter is to set out detailed instructions to Kyprianos Makrides & Partners ("KM&P") regarding the procedure for the forced sale of the entire shareholding of Korinthian Maritime Holdings Ltd. ("KMH") in Oceangate Ventures Ltd. ("Oceangate"), following the enforcement order granted by the Nicosia District Court on 30 September 2024 in Case No. 2247/2024.
As you are aware, the enforcement order in question was obtained to recognize and enforce LCIA Award No. 224718, dated 28 June 2024 (the "Award"), which was rendered in favour of TSL by a three-member tribunal seated in London. The Award was made in the total amount of £96,450,000 on the substantive claims, together with £12,150,000 in respect of the tribunal's costs award, yielding a total principal sum of £108,600,000 (the "Award Debt"). Post-award interest accrues on the full Award Debt at the rate of 5.25% per annum simple, calculated from 29 June 2024 until the date of full satisfaction of the Award.
The enforcement order was obtained by KM&P under the provisions of the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958), as implemented in the domestic law of the Republic of Cyprus through the International Commercial Arbitration Law (Law 101/1987) and the relevant provisions of the Arbitration Law, Cap. 4. We understand that the enforcement order was granted on an ex parte basis and is now operative. We further understand that no application to set aside the enforcement order has been filed by KMH or its legal advisers as at the date of this letter.
We also draw your attention to the freezing injunction that was granted on 12 August 2024 by the Nicosia District Court (the "Cyprus Freezing Injunction"), which operates over KMH's shareholding in Oceangate and over KMH's bank accounts maintained in Cyprus. The Cyprus Freezing Injunction, together with the worldwide freezing order previously granted in England on 16 July 2024 by Mr. Justice Ashworth of the Commercial Court (Claim No. CL-2024-000487), has been instrumental in preserving the target assets pending enforcement. We are now in a position to move to the execution phase, and we set out our instructions in detail below.
1. Background on Oceangate Ventures Ltd. and Target Assets
For the purposes of completeness, and to ensure that all relevant information is reflected in the forthcoming court applications, we set out the background to the target assets as follows.
1.1 Oceangate Ventures Ltd. is a private limited liability company incorporated in the Republic of Cyprus under Registration No. HE 401293. Its registered office is at 28 Themistokli Dervi Avenue, Suite 604, Nicosia 1066, Cyprus. Oceangate was incorporated on or about 14 March 2019 and remains active on the Cyprus Registrar of Companies register.
1.2 KMH, itself a company incorporated in the Republic of Cyprus under Registration No. HE 387421, with its registered office at 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus, holds 100% of the issued share capital of Oceangate. Based on the information available to us, the issued share capital of Oceangate comprises 10,000 ordinary shares of €1.00 nominal value each, all of which are registered in the name of KMH. There are no minority shareholders, and no other classes of shares have been issued.
1.3 Oceangate serves as an intermediate holding company within the broader corporate structure controlled by KMH. Specifically, Oceangate is the sole shareholder of Dnepr Shipholding Inc., a company incorporated in the British Virgin Islands under Company No. 2014876 ("Dnepr Shipholding"). Dnepr Shipholding is, in turn, the registered owner of the following vessels:
(a) M/V Aegean Fortuna (IMO No. 9784521), a Supramax Bulk Carrier of 58,200 DWT, registered under the flag of the Republic of the marshall Islands; and
(b) M/V Volga Spirit (IMO No. 9756892), a Panamax Bulk Carrier of 76,400 DWT, registered under the flag of the Republic of Cyprus.
1.4 The foregoing shareholding and vessel ownership structure has been confirmed through the independent asset tracing investigations conducted on behalf of TSL by Hartwell Pemberton LLP, specialist corporate intelligence and asset tracing consultants. Hartwell Pemberton produced a preliminary asset tracing report dated 15 August 2024, and an updated report incorporating further findings dated 1 October 2024. An extract of the updated report confirming the Oceangate corporate structure is enclosed with this letter for ease of reference and for use in the court proceedings.
1.5 The Oceangate shareholding constitutes a significant and valuable component of KMH's identifiable assets within the jurisdiction of the Republic of Cyprus. Given the value of the two vessels held through Dnepr Shipholding — which, based on Northcape Maritime Advisory Ltd.'s most recent desktop valuations, are collectively estimated at approximately US$42,000,000 to US$47,000,000 — the Oceangate shares represent the primary target for execution in Cyprus. Additional value may be attributable to Oceangate's cash balances and receivables, though we understand from the Hartwell Pemberton reports that the majority of the entity's value derives from its indirect vessel ownership.
1.6 For completeness, we note that KMH is ultimately beneficially owned by the Volkov family through a combination of BVI and Cypriot holding structures. Mr. Andrei Volkov is the ultimate beneficial owner ("UBO") and de facto director of the KMH group, exercising effective control over its operations and financial affairs. Mr. Sergei Volkov, Andrei Volkov's brother, serves as a named director of both KMH and Oceangate. This information is relevant to the history of asset dissipation that has been documented in these proceedings and in the English Commercial Court proceedings, as further discussed below.
2. Instructions for Initiating Forced Sale Proceedings
We instruct KM&P as follows in connection with the initiation of the forced sale process.
2.1 KM&P is instructed to apply immediately — and in any event within five (5) business days of the date of this letter — to the Nicosia District Court for an order for execution by forced sale of KMH's entire 100% shareholding in Oceangate Ventures Ltd. (being 10,000 ordinary shares of €1.00 nominal value each), pursuant to and in satisfaction of the enforcement order dated 30 September 2024 in Case No. 2247/2024 (the "Execution Application").
2.2 The Execution Application should clearly reference Case No. 2247/2024, the enforcement order of 30 September 2024, and the underlying LCIA Award No. 224718 dated 28 June 2024. Certified copies of both the enforcement order and the Award should be attached to the Execution Application as exhibits. We enclose certified copies of both documents with this letter for that purpose. If additional certifications, apostilles, or certified translations into Greek are required by the court, please arrange for these to be prepared as a matter of urgency and notify us of any associated costs.
2.3 We request that KM&P coordinate directly with the Cyprus court bailiff (the Dikastikos Epidotis) to initiate the execution process in accordance with the applicable provisions of the Civil Procedure Law of Cyprus (Cap. 6) and the Civil Procedure Rules. KM&P should take all necessary procedural steps to ensure that the bailiff is properly instructed and equipped with the required documentation to proceed with the seizure and sale of the shares.
2.4 The Execution Application should specify that the judgment debt in respect of which execution is sought is the full amount of the enforcement order — namely, £108,600,000 in principal, together with post-award interest at 5.25% per annum simple accruing from 29 June 2024 until the date of full satisfaction. However, KM&P should note that the judgment debt is subject to credit for amounts recovered in other jurisdictions. As at the date of this letter, the following partial recovery has been made:
(a) The sum of £18,720,000 has been recovered in England by way of a final third-party debt order made against Meridian Trust Bank Ltd., dated 3 September 2024, in the English Commercial Court proceedings (Claim No. CL-2024-000487). This amount has been received into TSL's solicitors' client account and credited against the Award Debt.
2.5 Accordingly, the outstanding balance of the Award Debt is approximately £89,880,000 in principal (before interest), plus accrued post-award interest. TSL reserves the right to update the outstanding balance at any time to reflect further recoveries in other jurisdictions. We will communicate promptly any additional recoveries made in the parallel enforcement proceedings in Singapore (Originating Summons No. 872/2024), the United Arab Emirates (Case No. 1893/2024, ADGM Courts), or elsewhere, so that the execution in Cyprus can proceed on the basis of accurate figures and to avoid any risk of double recovery.
2.6 Please revert at your earliest convenience with a detailed procedural timeline for the execution process, including: (i) the anticipated date for filing the Execution Application; (ii) the expected timeframe for the court's direction on the manner of execution; (iii) the advertisement requirements and their anticipated duration; and (iv) the projected date for the forced sale itself. An indicative timeline will assist TSL and C&H in coordinating the multi-jurisdictional enforcement strategy.
3. Valuation Requirements
3.1 We anticipate that the Nicosia District Court will require, or at minimum expect, an independent valuation of the Oceangate shares prior to ordering their sale, in order to establish a reserve price or to guide the forced sale process and ensure that the shares are not sold at an undervalue. We instruct KM&P to take all necessary steps to arrange for such a valuation on an expedited basis.
3.2 The valuation must take into account the nature of Oceangate as an intermediate holding company whose principal asset is its 100% shareholding in Dnepr Shipholding Inc. (BVI). The value of the Oceangate shares is therefore substantially determined by the value of Dnepr Shipholding's underlying assets, principally the two vessels, M/V Aegean Fortuna and M/V Volga Spirit, as well as any charter receivables, cash balances, and other assets or liabilities at the Dnepr Shipholding and Oceangate levels. The valuation should also address the existence of any encumbrances on the shares or on the vessels, including any ship mortgages or security interests that may be in place.
3.3 We note that Northcape Maritime Advisory Ltd. ("Northcape"), located at 3 Thomas More Square, London E1W 1WY, has previously provided vessel valuations in this matter. Should the Cyprus court require or accept a vessel-level valuation to underpin the share valuation, C&H is in a position to coordinate directly with Captain Ian Forsyth, Senior Valuation Surveyor at Northcape, to commission updated market value appraisals of both M/V Aegean Fortuna and M/V Volga Spirit. We would expect such updated valuations to be available within seven (7) to ten (10) business days of instruction.
3.4 If, however, the Nicosia District Court requires or prefers a valuation to be carried out by a Cyprus-based or Cyprus-registered valuation expert — whether for reasons of procedural formality, judicial preference, or local practice — we request that KM&P recommend a suitable expert. Please provide us with: (i) the name and credentials of the proposed valuer; (ii) the valuer's relevant experience in valuing corporate shareholdings and/or shipping assets; (iii) an estimated timeline for completion of the valuation; and (iv) a fee estimate for the engagement. C&H will review the recommendation promptly and provide approval or further direction.
3.5 We cannot overstate the importance of expedition in the valuation process. KMH has demonstrated a well-documented pattern of post-award asset dissipation, as evidenced by the findings in Hartwell Pemberton's reports and as recorded in the judgment of Mr. Justice Ashworth of 16 July 2024 granting the worldwide freezing order in the English proceedings. Among other things, the evidence before the English court disclosed that, within days of the Award being issued, KMH procured the transfer of approximately US$8,400,000 from Dnepr Shipholding's operating account at Tyche Bank (Cyprus) to an account held at a bank in Ras Al Khaimah in the name of a newly incorporated RAK ICC entity, Blacksea Trading & Logistics FZE, which appears to be controlled by Mr. Andrei Volkov. Any delay in completing the valuation and proceeding to the forced sale creates a risk that further steps will be taken to diminish the value of the assets, whether through the dissipation of charter revenues, the creation of spurious encumbrances, or other means.
4. Coordination with Court Bailiff and Sale Mechanism
We set out below detailed instructions for the practical steps involved in coordinating with the Cyprus court bailiff and effecting the forced sale.
4.1 Filing of the Execution Writ. KM&P should file the appropriate execution writ (or application for a warrant of execution, as the procedural form may require) with the Nicosia District Court, referencing the enforcement order in Case No. 2247/2024 and the Award. The execution writ should identify the specific property to be seized — namely, 10,000 ordinary shares of €1.00 nominal value each in Oceangate Ventures Ltd. (HE 401293), constituting 100% of the issued share capital, registered in the name of KMH.
4.2 Service of the Execution Writ. The execution writ should be served on:
(a) KMH, at its registered office at 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus; and
(b) Oceangate Ventures Ltd., at its registered office at 28 Themistokli Dervi Avenue, Suite 604, Nicosia 1066, Cyprus.
We note that both entities share the same building, and we anticipate that service can be effected simultaneously. If there are any difficulties in effecting service — for instance, if the registered offices are found to be vacant or if service is refused — please notify us immediately so that we may consider substituted service or other procedural options.
4.3 Notation on the Registrar of Companies Records. We instruct KM&P to ensure that the execution is formally noted on the records of the Cyprus Registrar of Companies in respect of Oceangate Ventures Ltd. (HE 401293). This notation is essential to prevent KMH or any person acting on its behalf from transferring, encumbering, or otherwise dealing with the Oceangate shares pending completion of the forced sale. Please confirm whether such notation can be effected by the court bailiff directly, or whether a separate application or notification to the Registrar is required. In either case, this step should be taken at the earliest possible opportunity.
4.4 Advertisement of the Forced Sale. The forced sale must be advertised in accordance with the requirements of Cypriot procedural law. We understand that this typically involves publication in the Official Gazette of the Republic of Cyprus (Episimi Efimerida tis Dimokratias) and in one or more local newspapers of general circulation. Please confirm the precise advertisement requirements, including: (i) the number of publications required; (ii) the mandatory notice period between publication and the date of sale; (iii) the form and content of the advertisement; and (iv) the estimated cost of publication. If there is any discretion as to the choice of newspaper, please select the publication most likely to reach potential purchasers of a shareholding in a shipping holding company.
4.5 Conduct of the Sale. We understand that under Cypriot law, the forced sale of shares may be conducted by public auction. If, however, the court permits a sale by private treaty — for instance, where the court is satisfied that a private sale would achieve a better price or a more efficient outcome — we would wish to explore that option. In the case of a public auction, we request that KM&P provide details of the auction process, including the venue, date, reserve price (as established by the independent valuation), and any conditions of sale. In the case of a private treaty sale, the sale price should in no event be less than the independently assessed fair market value of the shares, and any proposed purchaser should be vetted for financial capacity and absence of connections to KMH or the Volkov family.
4.6 Post-Sale Transfer. We request that KM&P confirm whether any consent or notification to the Registrar of Companies is required to transfer the Oceangate shares to the purchaser following the forced sale, and to take all necessary steps to ensure a clean and effective transfer. This includes arranging for the issuance of new share certificates in the name of the purchaser, updating the register of members of Oceangate, and filing any required returns with the Registrar. We need to ensure that the purchaser obtains unencumbered title to the shares free and clear of any claims by KMH, the Volkov family, or any third party.
4.7 Opposition by KMH. We are aware that KMH is represented in Cyprus by Vassiliadis & Economou LLC, located at 7 Stasinou Avenue, 3rd Floor, Nicosia 1060. The partners with conduct of the matter on behalf of KMH are Mr. Georgios Vassiliadis and Ms. Eleni Economou. We consider it likely that KMH and/or its counsel will seek to oppose or delay the forced sale, whether by challenging the enforcement order, seeking a stay of execution, or raising procedural objections. We instruct KM&P to vigorously resist any such application and to defend TSL's right to proceed with execution. In the event that any opposition is filed or threatened, please report the matter to C&H immediately, providing copies of all relevant filings and submissions, so that we may provide support and, if necessary, coordinate with our English proceedings team.
5. KMH Bank Accounts in Cyprus
5.1 In addition to the forced sale of Oceangate shares, KM&P is instructed to simultaneously pursue execution against KMH's Cyprus bank accounts that are subject to the Cyprus Freezing Injunction granted on 12 August 2024. We understand from the freezing injunction proceedings and from KMH's disclosure that the following accounts are held to KMH's credit in Cyprus:
(a) Account No. [details held on file] at Hellenic Commercial Bank Ltd., Nicosia Main Branch;
(b) Account No. [details held on file] at Tyche Bank (Cyprus) Ltd., Limassol Branch; and
(c) Any other accounts identified by KMH in its disclosure affidavit or subsequently discovered.
5.2 KM&P is instructed to apply for garnishment or attachment orders over all funds held to KMH's credit in the foregoing accounts, and in any other accounts that may be identified, to the extent that such funds are not already subject to an existing garnishment or execution order. The applications should be made promptly and in parallel with the Execution Application for the forced sale of the Oceangate shares.
5.3 All proceeds recovered from the garnishment of KMH's bank accounts should be remitted to TSL together with the proceeds of the share sale, as set out in Section 6 below.
6. Remittance of Proceeds
6.1 All proceeds from the forced sale of the Oceangate Ventures shares and from the garnishment of KMH's Cyprus bank accounts are to be remitted to TSL's designated recovery account. The relevant bank details are as follows:
Account Holder: Thalassa Shipping & Logistics SA
Bank: Ionian National Bank SA
Bank Address: 22 Stadiou Street, Athens 105 64, Greece
Account Number and IBAN: To be provided separately via secure communication.
6.2 C&H will send full wire transfer instructions under separate cover, transmitted via secure encrypted communication, or will confirm that the wire instructions previously provided to KM&P in connection with the freezing injunction proceedings remain current and valid. KM&P should not effect any remittance until written confirmation of the correct wire instructions has been received from C&H.
6.3 We instruct KM&P to ensure that the conversion from EUR to GBP — or, if TSL's account at Ionian National Bank is denominated in EUR or is capable of receiving EUR deposits, remittance in EUR — is handled at the most favorable exchange rate available at the time of remittance. Any currency conversion costs, wire transfer fees, or bank charges should be minimized to the greatest extent possible. If KM&P is in a position to select the conversion mechanism (for example, by directing the court-appointed fund custodian to convert via a competitive FX rate), please do so in TSL's interests.
6.4 Upon remittance, we request that KM&P provide C&H and TSL with a detailed accounting, in writing, setting out: (i) the gross proceeds of the share sale; (ii) the gross proceeds of any bank account garnishment; (iii) all deductions, itemized by category, including court fees, bailiff costs and commissions, valuation fees, advertisement costs, and any other disbursements; (iv) the net proceeds available for remittance; and (v) the exchange rate applied, the date and time of conversion, and the identity of the converting institution.
6.5 For the avoidance of doubt, all professional costs and fees of KM&P in connection with the execution proceedings — including court fees, disbursements, and KM&P's own time charges — will be billed separately to C&H in accordance with the existing fee arrangements between our respective firms. We note for internal purposes that KM&P's total estimated fees for the execution phase are €285,000, and any material deviation from this estimate should be flagged to C&H in advance of the costs being incurred.
7. Reporting and Coordination
7.1 We request that KM&P provide written progress reports to C&H on a weekly basis, every Friday by close of business (Nicosia time), until the execution proceedings are completed and all proceeds have been remitted to TSL. The weekly reports should cover, at a minimum: (i) the current procedural status of the Execution Application and any related applications; (ii) any filings made or orders received during the reporting week; (iii) any communications with KMH's counsel, Vassiliadis & Economou LLC; (iv) any issues or obstacles encountered; and (v) the anticipated next steps and timeline.
7.2 All substantive correspondence with Vassiliadis & Economou LLC, whether by letter, email, or otherwise, should be copied to C&H at the following addresses:
Hannah Brinkley, Lead Associate — h.brinkley@calderwoodharkness.com
Patrick Gallagher, Working Associate — p.gallagher@calderwoodharkness.com
Calderwood & Harkness LLP, 45 Moorgate, London EC2R 6AR, United Kingdom
7.3 Any court filings, orders, directions, or judgments received in the Cyprus proceedings should be forwarded to C&H immediately upon receipt, by email in the first instance with hard copies to follow by courier where originals are required.
7.4 We draw KM&P's attention to the fact that enforcement proceedings are being pursued in parallel in multiple jurisdictions, as follows:
(a) Singapore: Originating Summons No. 872/2024, with local counsel Straits Meridian LLP. In those proceedings, TSL obtained the arrest of M/V Crimson Horizon (IMO 9812347) on 20 August 2024, and the recognition and enforcement application is proceeding before the Singapore High Court. We await a hearing date.
(b) United Arab Emirates: Case No. 1893/2024 before the Abu Dhabi Global Market Courts, with local counsel Al-Rashid Hatem & Associates. A precautionary attachment order was granted on 28 August 2024 over certain KMH-related assets located in the UAE.
(c) England: Claim No. CL-2024-000487 in the Commercial Court. The worldwide freezing order granted by Mr. Justice Ashworth on 16 July 2024 remains in full force and effect. The third-party debt order against Meridian Trust Bank Ltd. has been satisfied as noted above. Further enforcement applications in England are under consideration.
7.5 KM&P should be mindful of this multi-jurisdictional context at all times and should inform the Nicosia District Court, as appropriate and as required by the court's rules or practice, of the steps being taken in other jurisdictions to avoid any risk of over-recovery or double recovery. C&H will keep KM&P updated on developments in the other enforcement proceedings that are material to the Cyprus execution.
7.6 We further instruct KM&P to maintain detailed and accurate contemporaneous time records for all work performed in connection with these execution proceedings. TSL intends to pursue KMH for the full costs of enforcement, including the costs incurred in Cyprus, and detailed time records will be necessary to support any costs application.
8. Urgency and Timeline
8.1 We wish to emphasize in the strongest terms that time is of the essence in this matter. KMH, under the direction of Mr. Andrei Volkov, has demonstrated a persistent and deliberate pattern of asset dissipation in the period following the issuance of the Award. The evidence placed before the English Commercial Court and the Nicosia District Court in support of the respective freezing injunctions documented multiple instances of asset transfers, corporate restructuring, and the movement of funds to jurisdictions with less robust enforcement mechanisms. Every day that passes without execution creates a risk that further steps will be taken — whether through the interposition of additional corporate layers, the creation of spurious security interests, or the physical relocation of vessels — to diminish the value of the assets available to satisfy the Award Debt.
8.2 We are particularly concerned about the position of M/V Volga Spirit (IMO 9756892), one of the two vessels held through Dnepr Shipholding Inc. under the Oceangate structure. According to the most recent AIS tracking data available to us, M/V Volga Spirit was last reported at anchorage at Fujairah, United Arab Emirates. There is a risk that this vessel may be moved to a jurisdiction where enforcement is more difficult, or that arrangements may be made to sell or refinance the vessel, thereby diminishing the value of the Oceangate shares that are the subject of the forced sale. The execution of the forced sale of the Oceangate shares should therefore be completed before any further restructuring or dissipation by KMH can take effect.
8.3 We request that KM&P aim to complete the entire forced sale process — from filing the Execution Application through to receipt of sale proceeds — within a period of four (4) to six (6) weeks, if procedurally possible. We recognise that this timeline is ambitious and depends on court scheduling, advertisement requirements, and the absence of significant opposition from KMH. We therefore request that KM&P revert at the earliest opportunity with a realistic assessment of the achievable timeline, together with any recommendations for procedural steps that might expedite the process.
Closing
We trust that the foregoing instructions are clear and comprehensive. Should KM&P require any clarification or wish to discuss any aspect of these instructions, we are available for a telephone or video conference at your convenience. Please do not hesitate to contact us directly at the details below.
The relevant contact details at C&H for this matter are as follows:
Hannah Brinkley, Lead Associate Direct Line: +44 (0)20 7946 8247
Email: h.brinkley@calderwoodharkness.com
Patrick Gallagher, Working Associate Direct Line: +44 (0)20 7946 8263
Email: p.gallagher@calderwoodharkness.com
The engagement is overseen by Samuel Eklund, Responsible Partner, who may be contacted at s.eklund@calderwoodharkness.com or on +44 (0)20 7946 8210 if required.
We look forward to receiving KM&P's confirmation of receipt of these instructions and an initial assessment of the procedural timeline at the earliest opportunity.
Yours faithfully,
CALDERWOOD & HARKNESS LLP
By: ________
Hannah Brinkley Lead Associate, Litigation (General) Calderwood & Harkness LLP 45 Moorgate, London EC2R 6AR United Kingdom
cc:
Samuel Eklund, Responsible Partner, Calderwood & Harkness LLP
Patrick Gallagher, Working Associate, Calderwood & Harkness LLP
Ioanna Christodoulou, General Counsel, Thalassa Shipping & Logistics SA, 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece
Andreas Kyprianos, Senior Partner, Kyprianos Makrides & Partners
Enclosures:
1. Certified copy of the Nicosia District Court enforcement order dated 30 September 2024 (Case No. 2247/2024)
2. Certified copy of LCIA Award No. 224718 dated 28 June 2024
3. Hartwell Pemberton LLP asset tracing report excerpt re: Oceangate Ventures Ltd. corporate structure (updated report dated 1 October 2024)
4. Copy of the Cyprus freezing injunction order dated 12 August 2024
5. Wire transfer instructions for TSL's recovery account at Ionian National Bank SA (to follow under separate secure cover)
This letter and its enclosures are strictly privileged and confidential, intended solely for the use of the addressee. If you have received this communication in error, please notify the sender immediately and destroy all copies. Any unauthorised use, disclosure, or distribution is strictly prohibited.

CALDERWOOD & HARKNESS LLP Solicitors & International Arbitration Counsel 45 Moorgate London EC2R 6AR United Kingdom

CALDERWOOD & HARKNESS LLP

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