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CALDERWOOD & HARKNESS LLP Solicitors & International Arbitration Counsel

45 Moorgate London EC2R 6AR United Kingdom

T: +44 (0)20 7496 8200 F: +44 (0)20 7496 8201 DX: 1044 London/City

www.calderwoodharkness.com

6 January 2025

WITHOUT PREJUDICE SAVE AS TO COSTS

BY FIRST CLASS POST, EMAIL (c.whitford@harknesswhitford.com), AND DX

Catherine Whitford Partner, International Arbitration Harkness Whitford & Co. 12 Fetter Lane London EC4A 1JP United Kingdom

Our Ref: SE/JMR/TSL-KMH/224718 Your Ref: CW/PB/KMH/2024-1147

Re: LCIA Arbitration No. 224718 — Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd. Commercial Court Claim No. CL-2024-000487

Dear Ms Whitford,

1. Privilege, Purpose, and Status of this Letter

We write without prejudice save as to costs, in accordance with the well-established principles set out in Calderbank v Calderbank [1976] Fam 93 and SG v SG (Costs) [2015] EWCA Civ 1003. This letter is intended to be referred to on questions of costs only, in any court and in any jurisdiction in which costs arising out of or in connection with the enforcement of LCIA Award No. 224718 fall for determination. It is not to be placed before any court or tribunal determining the merits of any issue save and except as to costs.

Samuel Eklund, Partner, writes on behalf of our client, Thalassa Shipping & Logistics SA ("TSL"), a société anonyme incorporated under the laws of the Hellenic Republic, in the matter of the enforcement of the final award dated 28 June 2024 rendered by the tribunal constituted under the auspices of the London Court of International Arbitration in LCIA Arbitration No. 224718 (the "Award").

This letter is addressed to Harkness Whitford & Co. in its capacity as the solicitors on record for Korinthian Maritime Holdings Ltd. ("KMH"), as identified in the proceedings before the Commercial Court of England and Wales under Claim No. CL-2024-000487 and in the related enforcement and freezing order applications in that Court.

The purpose of this letter is to set out a proposal for the resolution of the remaining outstanding amounts owed by KMH to TSL under the Award, with a view to bringing to an end the ongoing multi-jurisdictional enforcement campaign and avoiding the further accumulation of enforcement costs for both parties. We consider this proposal to be generous and reasonable in the circumstances, and we invite your client's serious and prompt consideration of its terms.

2. Background — The Award

On 28 June 2024, the tribunal constituted under LCIA Arbitration No. 224718 — comprising Sir Malcolm Fenton-Clarke (Presiding Arbitrator), Professor Athena Drakopoulos (TSL's nominee), and Dr Henrik Dalmqvist (KMH's nominee) — issued a unanimous final award in favour of TSL.

The tribunal found KMH liable to TSL across multiple heads of claim arising from KMH's breaches of three separate time charterparties, and awarded TSL the total sum of £96,450,000 in damages and interest, made up as follows:

(a) Damages for wrongful early redelivery of M/V Aegean Fortuna (IMO 9682451), in breach of the 60-month time charterparty dated 15 March 2019: £42,300,000;

(b) Outstanding hire arrears and damages for detention and misperformance in respect of M/V Crimson Horizon (IMO 9801334), arising under the 36-month time charterparty dated 22 September 2020: £28,150,000;

(c) Restitution of fabricated off-hire deductions wrongfully applied by KMH in respect of M/V Volga Spirit (IMO 9756892), under the 48-month time charterparty dated 8 January 2020: £2,740,000;

(d) Loss of profit and market differential damages, reflecting the difference between the charterparty rates and the prevailing market rates at the time of KMH's breaches, as assessed by the tribunal on the basis of expert evidence adduced by both parties: £16,480,000;

(e) Pre-award interest at the rate of 5.25% per annum simple, calculated from the respective dates of breach to the date of the Award: £6,780,000.

In addition, the tribunal allocated the costs of the arbitration 85% to KMH, ordering KMH to pay the sum of £12,150,000, comprising:

(a) LCIA administrative costs and tribunal fees: £3,240,000;

(b) TSL's reasonable legal costs of and incidental to the arbitration: £8,910,000.

Accordingly, the total amount awarded to TSL by the tribunal is £108,600,000, being the sum of the Award (£96,450,000) and the costs order (£12,150,000).

In addition, the tribunal directed that post-award interest shall accrue at the rate of 5.25% per annum simple on the unpaid Award sum of £96,450,000 from 29 June 2024 until the date of payment in full. At the daily rate of approximately £13,871.92 (i.e., £96,450,000 × 0.0525 ÷ 365), this represents a very significant continuing obligation for KMH. As of the date of this letter, the total post-award interest accrued on the full Award sum from 29 June 2024 to 6 January 2025 (a period of 192 days) amounts to approximately £2,663,408.22, before crediting any enforcement recoveries.

3. Summary of Enforcement Actions and Recoveries

Notwithstanding the clear and unambiguous terms of the Award, and despite a formal demand letter sent by this firm on 8 July 2024 calling upon KMH to satisfy the Award voluntarily within 14 days, KMH failed to make any payment whatsoever. This intransigence has compelled TSL to pursue enforcement across four jurisdictions, at very considerable cost and expense. We summarise the enforcement actions below.

3.1 England and Wales

TSL obtained the following relief from the Commercial Court:

(a) Worldwide Freezing Order ("WFO"): On 16 July 2024, Mr Justice Ashworth granted a worldwide freezing order against KMH on a without-notice basis, restraining KMH from dealing with, disposing of, or diminishing the value of its assets worldwide up to the value of £108,600,000. The WFO was continued at the return date hearing on 30 July 2024, at which KMH appeared by counsel (Mr Philip Hartley-Barnes KC, instructed by your firm) and did not oppose continuation. The WFO remains in full force and effect and imposes continuing disclosure obligations upon KMH, which KMH is required to comply with on an ongoing basis.

(b) Permission to Enforce under s. 66 Arbitration Act 1996: On 2 August 2024, TSL obtained permission to enforce the Award in the same manner as a judgment of the Commercial Court, pursuant to section 66 of the Arbitration Act 1996 (Claim No. CL-2024-000487). Judgment was entered in the terms of the Award.

(c) Set-Aside Application Dismissed: KMH issued an application to set aside the Award under sections 68 and 69 of the Arbitration Act 1996, alleging serious irregularity and error of law. That application was heard by Mr Justice Ashworth on 7–9 October 2024 and was dismissed in its entirety by judgment handed down on 11 October 2024. The learned judge found that there was no substance to either the section 68 or section 69 grounds, and he awarded TSL its costs of and occasioned by the set-aside application on the indemnity basis, noting that the application had been "without merit and advanced for the purpose of delay" (Judgment, paragraph 87). Those costs have been the subject of a detailed assessment and remain outstanding.

(d) Third-Party Debt Order — Meridian Trust Bank Ltd.: A final third-party debt order was made against Meridian Trust Bank Ltd. (50 Lombard Street, London EC2R 8AH) in respect of accounts held in the name of KMH. The sum of £18,720,000 was garnished and paid to TSL on 3 September 2024.

3.2 Cyprus.

(a) Recognition and Enforcement: TSL applied to the Nicosia District Court for recognition and enforcement of the Award pursuant to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958, as implemented in Cypriot law. By order dated 30 September 2024 (Case No. 2247/2024), the Nicosia District Court granted recognition and enforcement. An opposition application filed by KMH through its Cypriot legal representatives, Vassiliadis & Economou LLC, was heard and dismissed with costs.

(b) Freezing Injunction and Asset Recovery: A freezing injunction was obtained over the shares held by KMH in Oceangate Ventures Ltd. (Cyprus company registration number HE 401293), a Cypriot subsidiary of KMH holding significant maritime assets, as well as over KMH's bank accounts maintained with financial institutions in Limassol. Pursuant to enforcement orders, the Oceangate Ventures shares were subject to forced sale, and funds were recovered from the frozen bank accounts. Total recoveries in Cyprus amounted to approximately £22,350,000, with the enforcement process substantially completed by the end of November 2024.

TSL was represented in the Cypriot proceedings by Kyprianos Makrides & Partners, Advocates, Nicosia.

3.3 Singapore.

(a) Leave to Enforce: TSL obtained leave to enforce the Award in Singapore under the International Arbitration Act (Cap 143A) by order of the Singapore High Court (General Division) dated 6 September 2024 (OS 872/2024).

(b) Garnishee Order — Pinnacle Bank (Singapore) Ltd.: A garnishee order absolute was made against Pinnacle Bank (Singapore) Ltd. on 18 October 2024 in respect of accounts maintained by KMH and/or its subsidiaries with that bank. The sum of SGD $31,200,000 (equivalent to approximately £18,450,000 at the prevailing exchange rate) was received by TSL.

(c) Arrest and Judicial Sale of M/V *Crimson Horizon*: TSL arrested the M/V Crimson Horizon (IMO 9801334, Panamax Bulk Carrier, 82,100 DWT, marshall Islands flag) in the port of Singapore on 4 October 2024. The vessel was sold by judicial sale concluded on 15 November 2024, achieving a sale price of USD $22,800,000 (equivalent to approximately £18,330,000). The net proceeds of sale, after deduction of the Sheriff's fees and priority claims (if any), were received by TSL on 2 December 2024.

TSL was represented in the Singapore proceedings by Straits Meridian LLP, Advocates & Solicitors, Singapore.

3.4 United Arab Emirates

(a) Precautionary Attachment: TSL obtained a precautionary attachment order from the Dubai Court of First Instance on 28 August 2024 over the accounts of Korinthian DMCC (a Dubai-registered subsidiary of KMH) maintained at Emirates Gulf Commercial Bank PJSC, Dubai.

(b) Enforcement Order: An enforcement order was granted by the Dubai Court of First Instance (Case No. 1893/2024) on 20 November 2024, recognising and enforcing the Award in the UAE.

(c) Execution in Progress: Execution against the attached Korinthian DMCC accounts and receivables commenced on 10 December 2024 and is currently underway. Based on the information available to TSL and the precautionary attachment amounts, TSL anticipates recovering a further substantial sum from the UAE, although the precise quantum cannot yet be confirmed as at the date of this letter.

TSL is represented in the UAE proceedings by Al-Rashid Hatem & Associates, Legal Consultants, Dubai.

3.5 Professional Advisers

In addition to the engagement of local counsel in Cyprus, Singapore, and the UAE as identified above, TSL has been required to instruct:

(a) Hartwell Pemberton LLP, forensic accountants, for the purposes of tracing KMH's assets, analysing KMH's disclosure pursuant to the WFO, and identifying post-award asset movements and potential dissipation;

(b) Northcape Maritime Advisory Ltd., shipping valuation experts, for the purposes of vessel valuations in connection with the arrest and sale of M/V Crimson Horizon and the assessment of the value of M/V Volga Spirit.

The costs of these engagements, together with Calderwood & Harkness's own fees and disbursements in coordinating the multi-jurisdictional enforcement campaign, are very substantial indeed. We address this further below.

4. Current Financial Position — Amounts Recovered and Outstanding

4.1 Amounts Recovered to Date

As of the date of this letter, TSL has recovered the following amounts through enforcement:

The UAE recoveries are anticipated to yield a further material sum, but as execution remains in progress, the precise figure is not yet known. For the purposes of this letter, we proceed on the basis of confirmed recoveries of £77,850,000.

4.2 Total Amounts Owed by KMH

The total amounts owed by KMH to TSL under and in connection with the Award are as follows:

(a) Award sum: £96,450,000;

(b) Costs order: £12,150,000;

(c) Post-award interest at 5.25% per annum simple on the unpaid Award sum of £96,450,000 from 29 June 2024 to the date of payment, calculated in accordance with the formula: £96,450,000 × 0.0525 × (number of days elapsed / 365). Post-award interest will continue to accrue on any unpaid balance until payment in full.

For illustrative purposes, assuming a payment date of 27 January 2025 (being 21 days from the date of this letter), the post-award interest accrued on the full Award sum from 29 June 2024 to 27 January 2025 (213 days) would amount to approximately £2,954,813.01. The total due on that basis, before crediting enforcement recoveries, would be approximately £111,554,813.01.

4.3 Outstanding Balance

After crediting confirmed enforcement recoveries of £77,850,000, and subject to credit for any further UAE recoveries, the approximate outstanding balance as of a notional payment date of 27 January 2025 would be:

Total Award, Costs, and Interest: approximately £111,554,813.01

Less: Confirmed recoveries: £77,850,000

Less: Any further UAE recoveries (amount to be confirmed)

Approximate outstanding balance: £33,704,813.01 (subject to adjustment for UAE recoveries and the precise date of payment)

The precise figure will depend on the date of any voluntary payment by KMH and the quantum of recoveries achieved from the UAE enforcement, which will be credited to KMH's account as and when received. TSL will provide a detailed reconciliation upon request.

We observe that interest continues to accrue at the rate of approximately £13,871.92 per day on the full outstanding Award sum (or on such lesser sum as remains unpaid after applying recoveries in accordance with the usual rules of appropriation), and that every day of delay in payment increases KMH's liability.

5. Observations on KMH's Position and Continuing Costs Exposure

We invite your client to reflect carefully on the following matters.

First, KMH's application to set aside the Award under sections 68 and 69 of the Arbitration Act 1996 was dismissed by Mr Justice Ashworth on 11 October 2024, with costs awarded to TSL on the indemnity basis. The Award is final, binding, and enforceable. There is no extant challenge to the Award in any jurisdiction.

Second, enforcement orders have now been obtained in all four target jurisdictions — England and Wales, Cyprus, Singapore, and the United Arab Emirates. In Cyprus, KMH's opposition to enforcement (advanced through Vassiliadis & Economou LLC) was dismissed with costs. KMH has no realistic prospect of resisting enforcement in any jurisdiction.

Third, the worldwide freezing order granted by Mr Justice Ashworth on 16 July 2024 and continued on 30 July 2024 remains in full force and effect. KMH is under a continuing obligation to disclose its assets worldwide and to refrain from dealing with or diminishing the value of those assets. Compliance with this order is not optional, and any breach may give rise to contempt proceedings.

Fourth, TSL has identified further assets available for enforcement in the event that the outstanding balance is not satisfied voluntarily. These include, without limitation:

(a) M/V *Volga Spirit* (IMO 9756892, Panamax Bulk Carrier, 76,400 DWT, Cyprus flag), owned by Dnepr Shipholding Inc. (BVI Company No. 2014876), a wholly-owned subsidiary of KMH. The vessel was last reported at Fujairah anchorage and remains subject to potential arrest in any convenient jurisdiction. Northcape Maritime Advisory Ltd. has provided an indicative valuation of the vessel in the range of USD $18,000,000 to USD $21,500,000.

(b) Sub-charterer receivables owed to KMH and its subsidiaries under various sub-charter and contract of affreightment arrangements, estimated by Hartwell Pemberton LLP at approximately £4,200,000 in aggregate.

Fifth, continued enforcement will result in further and significant costs exposure for KMH, including:

(a) Additional legal costs incurred by TSL across multiple jurisdictions, which TSL will seek to recover from KMH. TSL's enforcement costs are already very substantial (as further addressed in Section 6 below) and will continue to increase with each additional step taken.

(b) TSL's entitlement to costs on the indemnity basis in England, as already ordered by Mr Justice Ashworth in respect of the set-aside application. TSL will contend that the same basis of assessment should apply to all enforcement costs in light of KMH's conduct.

(c) Contempt proceedings. TSL reserves the right to bring contempt proceedings against KMH and/or its directors and officers in the event that there is evidence of breach of the worldwide freezing order or further asset dissipation. In this regard, we note that the forensic analysis conducted by Hartwell Pemberton LLP has identified certain post-award asset movements by KMH and its subsidiaries which are the subject of ongoing investigation and which may form the basis of an application for committal. We put you on notice that TSL regards this matter with the utmost seriousness.

In summary, KMH faces the certainty of continuing enforcement against all of its remaining assets, the likelihood of substantial further costs liability, and the risk of contempt proceedings. TSL has demonstrated both the will and the resources to pursue enforcement to its conclusion, and will not hesitate to do so.

6. The Proposal

Against this background, and notwithstanding TSL's strong position, TSL is prepared to offer the following terms in the interests of achieving a prompt resolution and avoiding the further expenditure of time and costs by both parties. This proposal is open for acceptance for a period of 21 days from the date of this letter, expiring at 5:00 pm (London time) on 27 January 2025.

6.1 Payment of Outstanding Balance

KMH shall pay to TSL the full outstanding balance of the Award (being £96,450,000 less the aggregate of all amounts already recovered by TSL through enforcement proceedings), together with post-award interest accrued at the rate of 5.25% per annum simple on the unpaid Award sum from 29 June 2024 to the date of payment, calculated in accordance with the formula set out in the Award.

For the avoidance of doubt, the recoveries achieved by TSL to date will be credited against the Award sum and interest in accordance with the usual rules of appropriation, and a final reconciliation will be provided by TSL at the time of payment, taking into account any further UAE recoveries received in the interim.

6.2 Costs Concession

Under the terms of the Award, KMH is liable to pay the sum of £12,150,000 in respect of the costs of the arbitration. In addition, by reason of KMH's failure to satisfy the Award voluntarily and its active resistance to enforcement (including the unsuccessful set-aside application and the unsuccessful opposition in Cyprus), TSL has been compelled to incur very substantial post-award enforcement costs across four jurisdictions.

TSL's post-award enforcement costs — comprising Calderwood & Harkness LLP's own fees and disbursements, the fees and disbursements of local counsel in Cyprus (Kyprianos Makrides & Partners), Singapore (Straits Meridian LLP), and the UAE (Al-Rashid Hatem & Associates), the fees of Hartwell Pemberton LLP (forensic accountants), the fees of Northcape Maritime Advisory Ltd. (shipping valuation experts), court fees and filing fees in four jurisdictions, and all ancillary costs and disbursements — are estimated, as at the date of this letter, to exceed £5,000,000 and are continuing to increase. These are costs which TSL is entitled to seek to recover from KMH, and in respect of which TSL will contend that an indemnity basis of assessment is appropriate given KMH's conduct.

Notwithstanding the foregoing, and as a genuine concession, TSL is prepared to accept the following:

(a) KMH shall pay the tribunal costs of £12,150,000 as ordered in the Award (to the extent not already satisfied from enforcement recoveries credited against costs); and

(b) In consideration of such payment, TSL will forgo recovery of all additional post-award enforcement costs incurred by TSL across all four jurisdictions, being costs which TSL estimates exceed £5,000,000 and which would otherwise be recoverable from KMH in substantial part on an indemnity basis.

To state the position plainly: if this proposal is accepted and payment is received within the 21-day acceptance period, KMH's total costs liability will be limited to the £12,150,000 already ordered by the tribunal, and TSL will absorb its own enforcement costs in excess of £5,000,000. This represents a significant and tangible concession by TSL, reflecting its desire to bring this matter to a close without further expenditure of time and resources.

6.3 Discharge of Freezing Order and discontinuance

Upon receipt of payment of the full outstanding balance (Award, interest, and tribunal costs, less enforcement recoveries credited), TSL will:

(a) Apply to the Commercial Court of England and Wales for the discharge of the worldwide freezing order dated 16 July 2024 (as continued on 30 July 2024);

(b) Notify all courts in which enforcement proceedings are pending and apply for discontinuance, withdrawal, or termination of those proceedings as appropriate; and

(c) Instruct its local counsel in Cyprus, Singapore, and the UAE to take corresponding steps to conclude or withdraw all outstanding enforcement applications and processes in those jurisdictions.

6.4 Value of the Concession

To summarise the value of this proposal to KMH: TSL is prepared to forgo recovery of its post-award enforcement costs in excess of £5,000,000, which would otherwise be recoverable from KMH and which, given the indemnity costs order already made by Mr Justice Ashworth and the pattern of KMH's unreasonable resistance to enforcement, would likely be assessed at a very high proportion of the sums actually incurred.

The proposal therefore represents a genuine and substantial saving to KMH, offered in recognition of the practical desirability of bringing this matter to a prompt conclusion. It is made in good faith and on reasonable terms, and TSL respectfully urges KMH to accept it.

7. Consequences of Non-Acceptance

If this proposal is not accepted within the 21-day period (i.e., by 5:00 pm London time on 27 January 2025), TSL puts KMH on clear notice that:

(a) TSL will continue to pursue enforcement of the full Award, costs, and interest across all jurisdictions, without further notice to KMH, and will take all steps necessary and available to recover the totality of the sums owed;

(b) TSL will seek to arrest M/V *Volga Spirit* (IMO 9756892) and will pursue enforcement against all remaining KMH assets and receivables, wherever situated, including sub-charterer receivables and any assets not yet identified;

(c) TSL will seek recovery of all post-award enforcement costs from KMH, in addition to the £12,150,000 already awarded by the tribunal, on an indemnity basis in every jurisdiction in which such costs are recoverable;

(d) TSL will rely on this letter in support of any application for indemnity costs and/or enhanced costs orders in any jurisdiction, in accordance with the Calderbank principles;

(e) Post-award interest will continue to accrue on all unpaid sums at the rate of 5.25% per annum simple, in accordance with the terms of the Award, until payment in full; and

(f) TSL reserves the right to bring contempt proceedings and/or any other proceedings that may be warranted by the evidence, including in respect of any breach of the worldwide freezing order or any evidence of asset dissipation.

TSL reserves all of its rights in the event of non-acceptance. Nothing in this letter or in the proposal set out herein shall constitute a waiver, whether express or implied, of any right, remedy, claim, or entitlement available to TSL under the Award, under any court order, or under applicable law in any jurisdiction.

8. Mechanics of Payment

Any voluntary payment made by KMH in acceptance of this proposal should be made in pounds sterling by wire transfer to TSL's designated recovery account at:

Ionian National Bank SA 22 Stadiou Street Athens 105 64 Greece

Full bank account details and wire transfer instructions (including IBAN, SWIFT/BIC code, and beneficiary reference) will be provided promptly upon KMH's written confirmation of acceptance of this proposal.

Upon receipt of cleared funds representing payment in full of the outstanding balance (Award, interest, and tribunal costs, less enforcement recoveries credited as described above), TSL will take the steps described in Section 6.3 above, including applying for discharge of the worldwide freezing order, notifying all relevant courts, and instructing local counsel in all jurisdictions to bring the enforcement proceedings to a close.

9. Reservations

TSL expressly reserves all of its rights in respect of:

(a) The worldwide freezing order dated 16 July 2024 (as continued on 30 July 2024) and the disclosure obligations imposed on KMH thereunder, which remain fully operative unless and until discharged by the Court;

(b) Any contempt proceedings arising from breach of the worldwide freezing order or evidence of post-award asset dissipation, including as identified by the forensic analysis conducted by Hartwell Pemberton LLP;

(c) All enforcement proceedings currently pending or in progress in England and Wales, Cyprus, Singapore, and the United Arab Emirates, and any further enforcement proceedings that TSL may commence in any jurisdiction;

(d) Post-award interest continuing to accrue on all unpaid sums in accordance with the terms of the Award; and

(e) All other rights, remedies, claims, and entitlements available to TSL under the Award, under any court order, or under applicable law, whether or not expressly referred to in this letter.

Save as expressly set out in the proposal contained in Section 6 above, nothing in this letter constitutes or shall be construed as constituting an admission or concession by TSL on any matter whatsoever, whether as to fact, law, quantum, or otherwise.

This letter is written without prejudice save as to costs and may not be referred to, adduced, or relied upon in any proceedings other than on the question of costs.

10. Response

We request KMH's response to this proposal within 21 days of the date of this letter, being by no later than 5:00 pm (London time) on 27 January 2025. Any response should be addressed to:

Samuel Eklund Partner Calderwood & Harkness LLP 45 Moorgate London EC2R 6AR United Kingdom

Email: s.eklund@calderwoodharkness.com

DX: 1044 London/City

If a response is not received within that period, TSL will treat the proposal as rejected and will proceed with all available enforcement measures and costs applications accordingly, without further notice.

We trust that KMH and its advisers will give this proposal the serious and careful consideration it warrants.

Yours faithfully,

CALDERWOOD & HARKNESS LLP

By: ________

Samuel Eklund Partner, International Arbitration & Shipping Calderwood & Harkness LLP

Direct Line: +44 (0)20 7496 8247

Email: s.eklund@calderwoodharkness.com

cc: Ioanna Christodoulou, General Counsel, Thalassa Shipping & Logistics SA — for information only, sent by separate privileged cover

Enclosures: None

Calderwood & Harkness LLP is a limited liability partnership registered in England and Wales under number OC318476, with its registered office at 45 Moorgate, London EC2R 6AR. A list of members is available for inspection at that address. Calderwood & Harkness LLP is authorised and regulated by the Solicitors Regulation Authority (SRA No. 514287). This letter and any attachments are confidential and may be subject to legal professional privilege. If you have received this letter in error, please notify us immediately and destroy all copies.

Jurisdiction	Source	Amount Recovered
England & Wales	Garnishment — Meridian Trust Bank Ltd.	£18,720,000
Cyprus	Forced sale of Oceangate Ventures Ltd. shares and bank accounts	£22,350,000
Singapore	Garnishee order — Pinnacle Bank (Singapore) Ltd.	£18,450,000
Singapore	Judicial sale of M/V Crimson Horizon	£18,330,000
UAE	Execution in progress — recoveries anticipated but not yet received	To be confirmed
Total (confirmed recoveries)	£77,850,000

CALDERWOOD & HARKNESS LLP Solicitors & International Arbitration Counsel
45 Moorgate London EC2R 6AR United Kingdom
T: +44 (0)20 7496 8200 F: +44 (0)20 7496 8201 DX: 1044 London/City
www.calderwoodharkness.com
6 January 2025
WITHOUT PREJUDICE SAVE AS TO COSTS
BY FIRST CLASS POST, EMAIL (c.whitford@harknesswhitford.com), AND DX
Catherine Whitford Partner, International Arbitration Harkness Whitford & Co. 12 Fetter Lane London EC4A 1JP United Kingdom
Our Ref: SE/JMR/TSL-KMH/224718 Your Ref: CW/PB/KMH/2024-1147
Re: LCIA Arbitration No. 224718 — Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd. Commercial Court Claim No. CL-2024-000487
Dear Ms Whitford,
1. Privilege, Purpose, and Status of this Letter
We write without prejudice save as to costs, in accordance with the well-established principles set out in Calderbank v Calderbank [1976] Fam 93 and SG v SG (Costs) [2015] EWCA Civ 1003. This letter is intended to be referred to on questions of costs only, in any court and in any jurisdiction in which costs arising out of or in connection with the enforcement of LCIA Award No. 224718 fall for determination. It is not to be placed before any court or tribunal determining the merits of any issue save and except as to costs.
Samuel Eklund, Partner, writes on behalf of our client, Thalassa Shipping & Logistics SA ("TSL"), a société anonyme incorporated under the laws of the Hellenic Republic, in the matter of the enforcement of the final award dated 28 June 2024 rendered by the tribunal constituted under the auspices of the London Court of International Arbitration in LCIA Arbitration No. 224718 (the "Award").
This letter is addressed to Harkness Whitford & Co. in its capacity as the solicitors on record for Korinthian Maritime Holdings Ltd. ("KMH"), as identified in the proceedings before the Commercial Court of England and Wales under Claim No. CL-2024-000487 and in the related enforcement and freezing order applications in that Court.
The purpose of this letter is to set out a proposal for the resolution of the remaining outstanding amounts owed by KMH to TSL under the Award, with a view to bringing to an end the ongoing multi-jurisdictional enforcement campaign and avoiding the further accumulation of enforcement costs for both parties. We consider this proposal to be generous and reasonable in the circumstances, and we invite your client's serious and prompt consideration of its terms.
2. Background — The Award
On 28 June 2024, the tribunal constituted under LCIA Arbitration No. 224718 — comprising Sir Malcolm Fenton-Clarke (Presiding Arbitrator), Professor Athena Drakopoulos (TSL's nominee), and Dr Henrik Dalmqvist (KMH's nominee) — issued a unanimous final award in favour of TSL.
The tribunal found KMH liable to TSL across multiple heads of claim arising from KMH's breaches of three separate time charterparties, and awarded TSL the total sum of £96,450,000 in damages and interest, made up as follows:
(a) Damages for wrongful early redelivery of M/V Aegean Fortuna (IMO 9682451), in breach of the 60-month time charterparty dated 15 March 2019: £42,300,000;
(b) Outstanding hire arrears and damages for detention and misperformance in respect of M/V Crimson Horizon (IMO 9801334), arising under the 36-month time charterparty dated 22 September 2020: £28,150,000;
(c) Restitution of fabricated off-hire deductions wrongfully applied by KMH in respect of M/V Volga Spirit (IMO 9756892), under the 48-month time charterparty dated 8 January 2020: £2,740,000;
(d) Loss of profit and market differential damages, reflecting the difference between the charterparty rates and the prevailing market rates at the time of KMH's breaches, as assessed by the tribunal on the basis of expert evidence adduced by both parties: £16,480,000;
(e) Pre-award interest at the rate of 5.25% per annum simple, calculated from the respective dates of breach to the date of the Award: £6,780,000.
In addition, the tribunal allocated the costs of the arbitration 85% to KMH, ordering KMH to pay the sum of £12,150,000, comprising:
(a) LCIA administrative costs and tribunal fees: £3,240,000;
(b) TSL's reasonable legal costs of and incidental to the arbitration: £8,910,000.
Accordingly, the total amount awarded to TSL by the tribunal is £108,600,000, being the sum of the Award (£96,450,000) and the costs order (£12,150,000).
In addition, the tribunal directed that post-award interest shall accrue at the rate of 5.25% per annum simple on the unpaid Award sum of £96,450,000 from 29 June 2024 until the date of payment in full. At the daily rate of approximately £13,871.92 (i.e., £96,450,000 × 0.0525 ÷ 365), this represents a very significant continuing obligation for KMH. As of the date of this letter, the total post-award interest accrued on the full Award sum from 29 June 2024 to 6 January 2025 (a period of 192 days) amounts to approximately £2,663,408.22, before crediting any enforcement recoveries.
3. Summary of Enforcement Actions and Recoveries
Notwithstanding the clear and unambiguous terms of the Award, and despite a formal demand letter sent by this firm on 8 July 2024 calling upon KMH to satisfy the Award voluntarily within 14 days, KMH failed to make any payment whatsoever. This intransigence has compelled TSL to pursue enforcement across four jurisdictions, at very considerable cost and expense. We summarise the enforcement actions below.
3.1 England and Wales
TSL obtained the following relief from the Commercial Court:
(a) Worldwide Freezing Order ("WFO"): On 16 July 2024, Mr Justice Ashworth granted a worldwide freezing order against KMH on a without-notice basis, restraining KMH from dealing with, disposing of, or diminishing the value of its assets worldwide up to the value of £108,600,000. The WFO was continued at the return date hearing on 30 July 2024, at which KMH appeared by counsel (Mr Philip Hartley-Barnes KC, instructed by your firm) and did not oppose continuation. The WFO remains in full force and effect and imposes continuing disclosure obligations upon KMH, which KMH is required to comply with on an ongoing basis.
(b) Permission to Enforce under s. 66 Arbitration Act 1996: On 2 August 2024, TSL obtained permission to enforce the Award in the same manner as a judgment of the Commercial Court, pursuant to section 66 of the Arbitration Act 1996 (Claim No. CL-2024-000487). Judgment was entered in the terms of the Award.
(c) Set-Aside Application Dismissed: KMH issued an application to set aside the Award under sections 68 and 69 of the Arbitration Act 1996, alleging serious irregularity and error of law. That application was heard by Mr Justice Ashworth on 7–9 October 2024 and was dismissed in its entirety by judgment handed down on 11 October 2024. The learned judge found that there was no substance to either the section 68 or section 69 grounds, and he awarded TSL its costs of and occasioned by the set-aside application on the indemnity basis, noting that the application had been "without merit and advanced for the purpose of delay" (Judgment, paragraph 87). Those costs have been the subject of a detailed assessment and remain outstanding.
(d) Third-Party Debt Order — Meridian Trust Bank Ltd.: A final third-party debt order was made against Meridian Trust Bank Ltd. (50 Lombard Street, London EC2R 8AH) in respect of accounts held in the name of KMH. The sum of £18,720,000 was garnished and paid to TSL on 3 September 2024.
3.2 Cyprus.
(a) Recognition and Enforcement: TSL applied to the Nicosia District Court for recognition and enforcement of the Award pursuant to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958, as implemented in Cypriot law. By order dated 30 September 2024 (Case No. 2247/2024), the Nicosia District Court granted recognition and enforcement. An opposition application filed by KMH through its Cypriot legal representatives, Vassiliadis & Economou LLC, was heard and dismissed with costs.
(b) Freezing Injunction and Asset Recovery: A freezing injunction was obtained over the shares held by KMH in Oceangate Ventures Ltd. (Cyprus company registration number HE 401293), a Cypriot subsidiary of KMH holding significant maritime assets, as well as over KMH's bank accounts maintained with financial institutions in Limassol. Pursuant to enforcement orders, the Oceangate Ventures shares were subject to forced sale, and funds were recovered from the frozen bank accounts. Total recoveries in Cyprus amounted to approximately £22,350,000, with the enforcement process substantially completed by the end of November 2024.
TSL was represented in the Cypriot proceedings by Kyprianos Makrides & Partners, Advocates, Nicosia.
3.3 Singapore.
(a) Leave to Enforce: TSL obtained leave to enforce the Award in Singapore under the International Arbitration Act (Cap 143A) by order of the Singapore High Court (General Division) dated 6 September 2024 (OS 872/2024).
(b) Garnishee Order — Pinnacle Bank (Singapore) Ltd.: A garnishee order absolute was made against Pinnacle Bank (Singapore) Ltd. on 18 October 2024 in respect of accounts maintained by KMH and/or its subsidiaries with that bank. The sum of SGD $31,200,000 (equivalent to approximately £18,450,000 at the prevailing exchange rate) was received by TSL.
(c) Arrest and Judicial Sale of M/V *Crimson Horizon*: TSL arrested the M/V Crimson Horizon (IMO 9801334, Panamax Bulk Carrier, 82,100 DWT, marshall Islands flag) in the port of Singapore on 4 October 2024. The vessel was sold by judicial sale concluded on 15 November 2024, achieving a sale price of USD $22,800,000 (equivalent to approximately £18,330,000). The net proceeds of sale, after deduction of the Sheriff's fees and priority claims (if any), were received by TSL on 2 December 2024.
TSL was represented in the Singapore proceedings by Straits Meridian LLP, Advocates & Solicitors, Singapore.
3.4 United Arab Emirates
(a) Precautionary Attachment: TSL obtained a precautionary attachment order from the Dubai Court of First Instance on 28 August 2024 over the accounts of Korinthian DMCC (a Dubai-registered subsidiary of KMH) maintained at Emirates Gulf Commercial Bank PJSC, Dubai.
(b) Enforcement Order: An enforcement order was granted by the Dubai Court of First Instance (Case No. 1893/2024) on 20 November 2024, recognising and enforcing the Award in the UAE.
(c) Execution in Progress: Execution against the attached Korinthian DMCC accounts and receivables commenced on 10 December 2024 and is currently underway. Based on the information available to TSL and the precautionary attachment amounts, TSL anticipates recovering a further substantial sum from the UAE, although the precise quantum cannot yet be confirmed as at the date of this letter.
TSL is represented in the UAE proceedings by Al-Rashid Hatem & Associates, Legal Consultants, Dubai.
3.5 Professional Advisers
In addition to the engagement of local counsel in Cyprus, Singapore, and the UAE as identified above, TSL has been required to instruct:
(a) Hartwell Pemberton LLP, forensic accountants, for the purposes of tracing KMH's assets, analysing KMH's disclosure pursuant to the WFO, and identifying post-award asset movements and potential dissipation;
(b) Northcape Maritime Advisory Ltd., shipping valuation experts, for the purposes of vessel valuations in connection with the arrest and sale of M/V Crimson Horizon and the assessment of the value of M/V Volga Spirit.
The costs of these engagements, together with Calderwood & Harkness's own fees and disbursements in coordinating the multi-jurisdictional enforcement campaign, are very substantial indeed. We address this further below.
4. Current Financial Position — Amounts Recovered and Outstanding
4.1 Amounts Recovered to Date
As of the date of this letter, TSL has recovered the following amounts through enforcement:
The UAE recoveries are anticipated to yield a further material sum, but as execution remains in progress, the precise figure is not yet known. For the purposes of this letter, we proceed on the basis of confirmed recoveries of £77,850,000.
4.2 Total Amounts Owed by KMH
The total amounts owed by KMH to TSL under and in connection with the Award are as follows:
(a) Award sum: £96,450,000;
(b) Costs order: £12,150,000;
(c) Post-award interest at 5.25% per annum simple on the unpaid Award sum of £96,450,000 from 29 June 2024 to the date of payment, calculated in accordance with the formula: £96,450,000 × 0.0525 × (number of days elapsed / 365). Post-award interest will continue to accrue on any unpaid balance until payment in full.
For illustrative purposes, assuming a payment date of 27 January 2025 (being 21 days from the date of this letter), the post-award interest accrued on the full Award sum from 29 June 2024 to 27 January 2025 (213 days) would amount to approximately £2,954,813.01. The total due on that basis, before crediting enforcement recoveries, would be approximately £111,554,813.01.
4.3 Outstanding Balance
After crediting confirmed enforcement recoveries of £77,850,000, and subject to credit for any further UAE recoveries, the approximate outstanding balance as of a notional payment date of 27 January 2025 would be:
Total Award, Costs, and Interest: approximately £111,554,813.01
Less: Confirmed recoveries: £77,850,000
Less: Any further UAE recoveries (amount to be confirmed)
Approximate outstanding balance: £33,704,813.01 (subject to adjustment for UAE recoveries and the precise date of payment)
The precise figure will depend on the date of any voluntary payment by KMH and the quantum of recoveries achieved from the UAE enforcement, which will be credited to KMH's account as and when received. TSL will provide a detailed reconciliation upon request.
We observe that interest continues to accrue at the rate of approximately £13,871.92 per day on the full outstanding Award sum (or on such lesser sum as remains unpaid after applying recoveries in accordance with the usual rules of appropriation), and that every day of delay in payment increases KMH's liability.
5. Observations on KMH's Position and Continuing Costs Exposure
We invite your client to reflect carefully on the following matters.
First, KMH's application to set aside the Award under sections 68 and 69 of the Arbitration Act 1996 was dismissed by Mr Justice Ashworth on 11 October 2024, with costs awarded to TSL on the indemnity basis. The Award is final, binding, and enforceable. There is no extant challenge to the Award in any jurisdiction.
Second, enforcement orders have now been obtained in all four target jurisdictions — England and Wales, Cyprus, Singapore, and the United Arab Emirates. In Cyprus, KMH's opposition to enforcement (advanced through Vassiliadis & Economou LLC) was dismissed with costs. KMH has no realistic prospect of resisting enforcement in any jurisdiction.
Third, the worldwide freezing order granted by Mr Justice Ashworth on 16 July 2024 and continued on 30 July 2024 remains in full force and effect. KMH is under a continuing obligation to disclose its assets worldwide and to refrain from dealing with or diminishing the value of those assets. Compliance with this order is not optional, and any breach may give rise to contempt proceedings.
Fourth, TSL has identified further assets available for enforcement in the event that the outstanding balance is not satisfied voluntarily. These include, without limitation:
(a) M/V *Volga Spirit* (IMO 9756892, Panamax Bulk Carrier, 76,400 DWT, Cyprus flag), owned by Dnepr Shipholding Inc. (BVI Company No. 2014876), a wholly-owned subsidiary of KMH. The vessel was last reported at Fujairah anchorage and remains subject to potential arrest in any convenient jurisdiction. Northcape Maritime Advisory Ltd. has provided an indicative valuation of the vessel in the range of USD $18,000,000 to USD $21,500,000.
(b) Sub-charterer receivables owed to KMH and its subsidiaries under various sub-charter and contract of affreightment arrangements, estimated by Hartwell Pemberton LLP at approximately £4,200,000 in aggregate.
Fifth, continued enforcement will result in further and significant costs exposure for KMH, including:
(a) Additional legal costs incurred by TSL across multiple jurisdictions, which TSL will seek to recover from KMH. TSL's enforcement costs are already very substantial (as further addressed in Section 6 below) and will continue to increase with each additional step taken.
(b) TSL's entitlement to costs on the indemnity basis in England, as already ordered by Mr Justice Ashworth in respect of the set-aside application. TSL will contend that the same basis of assessment should apply to all enforcement costs in light of KMH's conduct.
(c) Contempt proceedings. TSL reserves the right to bring contempt proceedings against KMH and/or its directors and officers in the event that there is evidence of breach of the worldwide freezing order or further asset dissipation. In this regard, we note that the forensic analysis conducted by Hartwell Pemberton LLP has identified certain post-award asset movements by KMH and its subsidiaries which are the subject of ongoing investigation and which may form the basis of an application for committal. We put you on notice that TSL regards this matter with the utmost seriousness.
In summary, KMH faces the certainty of continuing enforcement against all of its remaining assets, the likelihood of substantial further costs liability, and the risk of contempt proceedings. TSL has demonstrated both the will and the resources to pursue enforcement to its conclusion, and will not hesitate to do so.
6. The Proposal
Against this background, and notwithstanding TSL's strong position, TSL is prepared to offer the following terms in the interests of achieving a prompt resolution and avoiding the further expenditure of time and costs by both parties. This proposal is open for acceptance for a period of 21 days from the date of this letter, expiring at 5:00 pm (London time) on 27 January 2025.
6.1 Payment of Outstanding Balance
KMH shall pay to TSL the full outstanding balance of the Award (being £96,450,000 less the aggregate of all amounts already recovered by TSL through enforcement proceedings), together with post-award interest accrued at the rate of 5.25% per annum simple on the unpaid Award sum from 29 June 2024 to the date of payment, calculated in accordance with the formula set out in the Award.
For the avoidance of doubt, the recoveries achieved by TSL to date will be credited against the Award sum and interest in accordance with the usual rules of appropriation, and a final reconciliation will be provided by TSL at the time of payment, taking into account any further UAE recoveries received in the interim.
6.2 Costs Concession
Under the terms of the Award, KMH is liable to pay the sum of £12,150,000 in respect of the costs of the arbitration. In addition, by reason of KMH's failure to satisfy the Award voluntarily and its active resistance to enforcement (including the unsuccessful set-aside application and the unsuccessful opposition in Cyprus), TSL has been compelled to incur very substantial post-award enforcement costs across four jurisdictions.
TSL's post-award enforcement costs — comprising Calderwood & Harkness LLP's own fees and disbursements, the fees and disbursements of local counsel in Cyprus (Kyprianos Makrides & Partners), Singapore (Straits Meridian LLP), and the UAE (Al-Rashid Hatem & Associates), the fees of Hartwell Pemberton LLP (forensic accountants), the fees of Northcape Maritime Advisory Ltd. (shipping valuation experts), court fees and filing fees in four jurisdictions, and all ancillary costs and disbursements — are estimated, as at the date of this letter, to exceed £5,000,000 and are continuing to increase. These are costs which TSL is entitled to seek to recover from KMH, and in respect of which TSL will contend that an indemnity basis of assessment is appropriate given KMH's conduct.
Notwithstanding the foregoing, and as a genuine concession, TSL is prepared to accept the following:
(a) KMH shall pay the tribunal costs of £12,150,000 as ordered in the Award (to the extent not already satisfied from enforcement recoveries credited against costs); and
(b) In consideration of such payment, TSL will forgo recovery of all additional post-award enforcement costs incurred by TSL across all four jurisdictions, being costs which TSL estimates exceed £5,000,000 and which would otherwise be recoverable from KMH in substantial part on an indemnity basis.
To state the position plainly: if this proposal is accepted and payment is received within the 21-day acceptance period, KMH's total costs liability will be limited to the £12,150,000 already ordered by the tribunal, and TSL will absorb its own enforcement costs in excess of £5,000,000. This represents a significant and tangible concession by TSL, reflecting its desire to bring this matter to a close without further expenditure of time and resources.
6.3 Discharge of Freezing Order and discontinuance
Upon receipt of payment of the full outstanding balance (Award, interest, and tribunal costs, less enforcement recoveries credited), TSL will:
(a) Apply to the Commercial Court of England and Wales for the discharge of the worldwide freezing order dated 16 July 2024 (as continued on 30 July 2024);
(b) Notify all courts in which enforcement proceedings are pending and apply for discontinuance, withdrawal, or termination of those proceedings as appropriate; and
(c) Instruct its local counsel in Cyprus, Singapore, and the UAE to take corresponding steps to conclude or withdraw all outstanding enforcement applications and processes in those jurisdictions.
6.4 Value of the Concession
To summarise the value of this proposal to KMH: TSL is prepared to forgo recovery of its post-award enforcement costs in excess of £5,000,000, which would otherwise be recoverable from KMH and which, given the indemnity costs order already made by Mr Justice Ashworth and the pattern of KMH's unreasonable resistance to enforcement, would likely be assessed at a very high proportion of the sums actually incurred.
The proposal therefore represents a genuine and substantial saving to KMH, offered in recognition of the practical desirability of bringing this matter to a prompt conclusion. It is made in good faith and on reasonable terms, and TSL respectfully urges KMH to accept it.
7. Consequences of Non-Acceptance
If this proposal is not accepted within the 21-day period (i.e., by 5:00 pm London time on 27 January 2025), TSL puts KMH on clear notice that:
(a) TSL will continue to pursue enforcement of the full Award, costs, and interest across all jurisdictions, without further notice to KMH, and will take all steps necessary and available to recover the totality of the sums owed;
(b) TSL will seek to arrest M/V *Volga Spirit* (IMO 9756892) and will pursue enforcement against all remaining KMH assets and receivables, wherever situated, including sub-charterer receivables and any assets not yet identified;
(c) TSL will seek recovery of all post-award enforcement costs from KMH, in addition to the £12,150,000 already awarded by the tribunal, on an indemnity basis in every jurisdiction in which such costs are recoverable;
(d) TSL will rely on this letter in support of any application for indemnity costs and/or enhanced costs orders in any jurisdiction, in accordance with the Calderbank principles;
(e) Post-award interest will continue to accrue on all unpaid sums at the rate of 5.25% per annum simple, in accordance with the terms of the Award, until payment in full; and
(f) TSL reserves the right to bring contempt proceedings and/or any other proceedings that may be warranted by the evidence, including in respect of any breach of the worldwide freezing order or any evidence of asset dissipation.
TSL reserves all of its rights in the event of non-acceptance. Nothing in this letter or in the proposal set out herein shall constitute a waiver, whether express or implied, of any right, remedy, claim, or entitlement available to TSL under the Award, under any court order, or under applicable law in any jurisdiction.
8. Mechanics of Payment
Any voluntary payment made by KMH in acceptance of this proposal should be made in pounds sterling by wire transfer to TSL's designated recovery account at:
Ionian National Bank SA 22 Stadiou Street Athens 105 64 Greece
Full bank account details and wire transfer instructions (including IBAN, SWIFT/BIC code, and beneficiary reference) will be provided promptly upon KMH's written confirmation of acceptance of this proposal.
Upon receipt of cleared funds representing payment in full of the outstanding balance (Award, interest, and tribunal costs, less enforcement recoveries credited as described above), TSL will take the steps described in Section 6.3 above, including applying for discharge of the worldwide freezing order, notifying all relevant courts, and instructing local counsel in all jurisdictions to bring the enforcement proceedings to a close.
9. Reservations
TSL expressly reserves all of its rights in respect of:
(a) The worldwide freezing order dated 16 July 2024 (as continued on 30 July 2024) and the disclosure obligations imposed on KMH thereunder, which remain fully operative unless and until discharged by the Court;
(b) Any contempt proceedings arising from breach of the worldwide freezing order or evidence of post-award asset dissipation, including as identified by the forensic analysis conducted by Hartwell Pemberton LLP;
(c) All enforcement proceedings currently pending or in progress in England and Wales, Cyprus, Singapore, and the United Arab Emirates, and any further enforcement proceedings that TSL may commence in any jurisdiction;
(d) Post-award interest continuing to accrue on all unpaid sums in accordance with the terms of the Award; and
(e) All other rights, remedies, claims, and entitlements available to TSL under the Award, under any court order, or under applicable law, whether or not expressly referred to in this letter.
Save as expressly set out in the proposal contained in Section 6 above, nothing in this letter constitutes or shall be construed as constituting an admission or concession by TSL on any matter whatsoever, whether as to fact, law, quantum, or otherwise.
This letter is written without prejudice save as to costs and may not be referred to, adduced, or relied upon in any proceedings other than on the question of costs.
10. Response
We request KMH's response to this proposal within 21 days of the date of this letter, being by no later than 5:00 pm (London time) on 27 January 2025. Any response should be addressed to:
Samuel Eklund Partner Calderwood & Harkness LLP 45 Moorgate London EC2R 6AR United Kingdom
Email: s.eklund@calderwoodharkness.com
DX: 1044 London/City
If a response is not received within that period, TSL will treat the proposal as rejected and will proceed with all available enforcement measures and costs applications accordingly, without further notice.
We trust that KMH and its advisers will give this proposal the serious and careful consideration it warrants.
Yours faithfully,
CALDERWOOD & HARKNESS LLP
By: ________
Samuel Eklund Partner, International Arbitration & Shipping Calderwood & Harkness LLP
Direct Line: +44 (0)20 7496 8247
Email: s.eklund@calderwoodharkness.com
cc: Ioanna Christodoulou, General Counsel, Thalassa Shipping & Logistics SA — for information only, sent by separate privileged cover
Enclosures: None
Calderwood & Harkness LLP is a limited liability partnership registered in England and Wales under number OC318476, with its registered office at 45 Moorgate, London EC2R 6AR. A list of members is available for inspection at that address. Calderwood & Harkness LLP is authorised and regulated by the Solicitors Regulation Authority (SRA No. 514287). This letter and any attachments are confidential and may be subject to legal professional privilege. If you have received this letter in error, please notify us immediately and destroy all copies.
Jurisdiction | Source | Amount Recovered
England & Wales | Garnishment — Meridian Trust Bank Ltd. | £18,720,000
Cyprus | Forced sale of Oceangate Ventures Ltd. shares and bank accounts | £22,350,000
Singapore | Garnishee order — Pinnacle Bank (Singapore) Ltd. | £18,450,000
Singapore | Judicial sale of M/V Crimson Horizon | £18,330,000
UAE | Execution in progress — recoveries anticipated but not yet received | To be confirmed
Total (confirmed recoveries) | £77,850,000

CALDERWOOD & HARKNESS LLP Solicitors & International Arbitration Counsel

WITHOUT PREJUDICE SAVE AS TO COSTS

CALDERWOOD & HARKNESS LLP

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