1044-00005 · Client 1044 · Engagement & Administration

dormancy-status-memorandum.docx DOCUMENT Finance & Banking

20 / 35 ← → ✕

CALDERWOOD & HARKNESS LLP

Brussels

CONFIDENTIAL — INTERNAL

MEMORANDUM

TO: James Prentice, Partner, International Trade & Sanctions Group Sandra Tung, Partner, International Trade & Sanctions Group

FROM: Christy Bauer, Senior Associate, intellectual Property Group Garrett Simmons, Associate, Tax Group

DATE: April 10, 2023

RE: Matter Dormancy Status — C&H-2022-ITS-04781 (Thalassa Shipping & Logistics SA — Customs Classification and Valuation Dispute)

This memorandum recommends and documents the placement of the above-referenced matter into dormant status. It summarizes the basis for dormancy, sets forth the current posture of the matter, establishes monitoring protocols to be observed during the dormant period, identifies tickler dates for proactive review, and defines the triggers under which the matter shall be reactivated. The memorandum is intended to serve as the definitive internal record of the matter's status as of the date hereof and to ensure continuity of service in the event of future reactivation.

I. Basis for Dormancy

Effective as of the date of this memorandum, Matter No. C&H-2022-ITS-04781 is being placed in dormant status. This determination is based on the confluence of four factors, each of which is described in detail below. In combination, these factors establish that no productive substantive work can be advanced at this time, that the client's rights and positions are fully preserved through existing agreements and filings, and that the matter is in a posture that warrants monitoring rather than active engagement.

A. BTI Application Pending at DG TAXUD

The central driver of the dormancy determination is the pendency of the Binding Tariff Information application before the European Commission's Directorate-General for Taxation and Customs Union ("DG TAXUD"), for which no timeline for resolution has been provided and over which neither the firm nor the client has meaningful procedural control.

BTI Application No. BTI-GR-2022-003847 was filed with the Independent Authority for Public Revenue of the Hellenic Republic ("AADE") on November 15, 2022, requesting a binding classification determination for the twenty units of automated port handling equipment at issue in this matter — specifically, twelve ship-to-shore ("STS") gantry cranes and eight automated stacking crane ("ASC") systems imported by Thalassa Shipping & Logistics SA ("TSL") through the Port of Piraeus between 2018 and 2021.

On February 7, 2023, AADE referred the BTI application to DG TAXUD for consultation, pursuant to Article 34(10) of the Union Customs Code (Regulation (EU) No. 952/2013) ("UCC"). The referral was triggered by the existence of divergent BTI rulings issued by other Member State customs authorities addressing substantially similar equipment. Specifically, the Netherlands customs authority issued BTI Ruling No. NL-BTI-2021-01234, classifying comparable STS cranes and ASC systems under Combined Nomenclature headings 8426 41 00 (for STS cranes — self-propelled, on wheels) and 8426 19 00 (for ASC systems — other overhead travelling cranes), both of which carry a conventional duty rate of 0%. In contrast, the German customs authority issued BTI Ruling No. DE-BTI-2020-05678, classifying ASC systems under CN heading 8428 90 90 (other lifting, handling, loading, or unloading machinery — other), which carries a conventional duty rate of 2.2%. The existence of these conflicting rulings required AADE to seek a uniform classification position from DG TAXUD before issuing its own BTI determination, in accordance with the procedural obligations set forth in the UCC Implementing Regulation.

As of the date of this memorandum, DG TAXUD has not provided any indication of the expected timeline for its consultation. No acknowledgment of the referral has been issued to TSL or its advisors, and AADE has confirmed only that the matter is "under consideration at the Commission level." Based on our review of historical precedent involving DG TAXUD classification consultations — including consultations on the classification of automated guided vehicles (2017–2019), remotely operated container spreaders (2019–2021), and semi-automated reach stackers (2020–2022) — the typical duration of such consultations ranges from twelve to twenty-four months. In certain cases involving complex technical assessments or the need for input from the Customs Code Committee (Section for Tariff and Statistical Nomenclature — formerly the Nomenclature Committee), consultations have extended beyond twenty-four months.

Accordingly, the estimated resolution window for the DG TAXUD consultation is Q1 2024 through Q1 2025, and potentially later. Until DG TAXUD provides its consultation opinion or guidance, AADE is unlikely to issue a BTI ruling, and the classification dispute — which constitutes the central legal question in this matter and drives the vast majority of the assessed additional duties — will remain unresolved.

B. Standstill Agreement in Effect

The enforcement posture of this matter is currently governed by a standstill agreement that suspends all collection and enforcement activity by AADE for the duration of the DG TAXUD consultation, thereby eliminating the immediate litigation pressure that would otherwise necessitate active engagement.

The standstill agreement between TSL and AADE was executed on March 1, 2023. The agreement was negotiated through an exchange of correspondence between Calderwood & Harkness LLP (on behalf of TSL, in coordination with local counsel Vournas & Theodorakis) and Meridian & Drakos Dikigiriko Grafeio (as external legal advisors to AADE). The standstill agreement was countersigned by Panagiotis Drakos, Senior Partner of Meridian & Drakos, on behalf of AADE's legal representation, and by Aikaterini Vlachopoulou, Chief Customs Auditor of the AADE Piraeus Regional Customs Office, on behalf of AADE in its administrative capacity.

The key terms of the standstill agreement are as follows:

(a) Enforcement Suspension. AADE agrees that it will not enforce, execute upon, or take any collection action with respect to Additional Duty Assessment Notice No. AADE/ADAN/2022/0073 (addressing the classification dispute) or Additional Duty Assessment Notice No. AADE/ADAN/2022/0074 (addressing the valuation dispute) for the duration of the standstill period.

(b) Security. TSL has posted a bank guarantee in the amount of €5,000,000 as security for the assessed amounts during the standstill period. The guarantee was issued by Compass Maritime Bank SA under Guarantee No. CMB-BG-2023-0291, dated March 10, 2023, and is payable on first demand to AADE in the event of a termination of the standstill followed by a final, non-appealable determination in AADE's favor.

(c) Administrative Proceedings in Abeyance. The proceedings before the Directorate of Resolution of Disputes ("DED") on TSL's administrative objections (filed November 30, 2022) are held in abeyance for the duration of the standstill period. No hearings will be scheduled, and no further submissions will be required, unless the standstill is terminated.

(d) Duration and Termination. The standstill continues in effect until the earliest of: (i) DG TAXUD issues a consultation opinion or classification guidance addressing the classification of the equipment at issue; (ii) AADE issues a BTI ruling in response to Application No. BTI-GR-2022-003847; or (iii) either party terminates the standstill upon sixty (60) days' written notice to the other party.

(e) Interest Accrual. Statutory interest continues to accrue on the disputed additional duties at the rate of 0.73% per month during the standstill period. The agreement expressly provides that the standstill does not constitute a waiver of AADE's right to collect accrued interest in the event of a final determination in its favor.

(f) Preservation of Rights. Both parties preserve all rights, claims, and defenses, including TSL's right to appeal any adverse DED decision or BTI ruling to the Administrative Court of First Instance of Piraeus.

The standstill agreement provides TSL with the procedural breathing room necessary to await the outcome of the DG TAXUD consultation without the risk of enforcement action. The bank guarantee, while representing a significant commitment of TSL's credit capacity, secures AADE's position and was a necessary condition for AADE's agreement to the standstill.

C. All Core Work Product Delivered

All substantive work product associated with the engagement through the current phase has been completed and delivered. The matter was structured in two phases: Phase 1 (assessment, analysis, and strategy development, covering the period from engagement through the filing of the BTI application and administrative objections) and Phase 2 (BTI prosecution, standstill negotiation, and related third-party notifications). Both phases are complete. The full inventory of deliverables is as follows:

Phase 1 — Assessment, Analysis, and Strategy:

1. Preliminary Case Assessment Memorandum — delivered October 14, 2022

2. Classification Analysis Memorandum — delivered November 8, 2022

3. Customs Valuation Analysis Memorandum — delivered November 10, 2022

4. Nereus Related-Party Analysis Memorandum — delivered November 18, 2022

5. Technology License Agreement Analysis Memorandum — delivered November 22, 2022

6. Penalty Exposure & Mitigation Memorandum — delivered November 25, 2022

7. Insurance Coverage Analysis Memorandum — delivered December 2, 2022

8. Financial Covenant Impact Memorandum — delivered December 5, 2022

9. Comparative BTI Rulings Analysis Memorandum — delivered December 8, 2022

10. Peloros Customs Agency Indemnification Rights Memorandum — delivered December 12, 2022

Phase 2 — Filings, Negotiations, and Third-Party Notifications:

11. BTI Application (including Draft Application, Technical Annex, and Legal Argument Annex) — filed with AADE on November 15, 2022

12. Administrative Objection to AADE/ADAN/2022/0073 (Classification) — filed with DED on November 30, 2022

13. Administrative Objection to AADE/ADAN/2022/0074 (Valuation) — filed with DED on November 30, 2022

14. Standstill Agreement Letter — executed March 1, 2023

15. Supplemental Submission to DG TAXUD — filed March 15, 2023

16. Response to AADE Information Request — submitted January 18, 2023

17. Client Update Letters — issued October 2022, November 2022, February 2023, and March 2023

18. Letter to Compass Maritime Bank SA — material litigation disclosure — sent October 3, 2022

19. Notice of Claim to Oceanos Underwriters SA (submitted via Aether Insurance Brokers Ltd.) — sent October 15, 2022

20. Response to Oceanos Reservation of Rights Letter — sent December 12, 2022

21. Demand and Preservation Letter to Peloros Customs Agency S.A. — sent December 15, 2022

22. Document Preservation Notice to TSL — sent October 20, 2022

23. Expert Retention Letters — Argonaut Trade Consulting GmbH (sent October 5, 2022; countersigned October 10, 2022) and Kestrel & Palladian LLP (sent October 5, 2022; countersigned October 11, 2022)

24. Local Counsel Retention Letter — Vournas & Theodorakis (sent September 28, 2022; countersigned October 2, 2022)

All deliverables have been indexed, filed in the document management system, and confirmed as received by the intended recipients. No outstanding deliverables remain.

D. No Active Substantive Tasks Pending

As of the date of this memorandum, there are no outstanding filings, deadlines, or substantive work requests on this matter. The matter is in a holding posture, awaiting external events — principally the outcome of the DG TAXUD classification consultation and any communications that AADE may issue in connection with the BTI application, the standstill, or the administrative objections.

All expert reports have been either finalized or brought to a stage of completion sufficient for the current phase of the matter. The classification expert report prepared by Dr. Lukas Brenner of Argonaut Trade Consulting GmbH (Munich) — addressing the technical characteristics and functional design of the STS cranes and ASC systems and their proper classification under the Combined Nomenclature — was finalized in November 2022 and submitted as the Technical Annex to the BTI Application. The customs valuation expert report prepared by Spyros Makris of Kestrel & Palladian LLP (London) — addressing the proper treatment of the technology license fees, Nereus procurement fees, and commissioning services under Articles 70–74 of the UCC and the related implementing provisions — is in final draft form sufficient for the current stage, with minor revisions to be made if and when the matter reactivates for DED proceedings or judicial appeal.

No action by the engagement team will materially advance the matter's resolution until one or more of the reactivation triggers described in Section V of this memorandum occurs.

II. Summary of Matter Status at Dormancy

The following table provides a consolidated summary of the key facts, parties, and current posture of the matter as of the date of dormancy:

The foregoing summary reflects the matter's posture as of April 10, 2023. All figures are based on the most recent information available and are subject to update upon reactivation.

III. Dormancy Monitoring Protocols

Although the matter is being placed in dormant status, ongoing monitoring is essential to protect TSL's legal rights, preserve the standstill, track accruing interest exposure, and ensure that any reactivation trigger is promptly identified and acted upon. The following monitoring protocols shall remain in effect for the duration of the dormant period. Each protocol identifies the responsible team member, the frequency of the monitoring activity, and the specific actions to be taken.

A. DG TAXUD Monitoring

Responsible: Christy Bauer, Senior Associate

Frequency: Monthly

Actions: The following monitoring activities shall be performed on or about the first business day of each calendar month:

(i) Review the Official Journal of the European Union for any classification regulations published by the European Commission under Article 57(4) of the UCC addressing the classification of STS gantry cranes, ASC systems, automated port handling equipment, or related goods under Combined Nomenclature headings 8426 or 8428.

(ii) Monitor the meeting agendas and published minutes of the Customs Code Committee, Section for Tariff and Statistical Nomenclature, for any agenda items or discussion points relating to the classification of lifting, handling, or loading equipment, including STS cranes and ASC systems. Meeting agendas are typically published on the European Commission's comitology register approximately two weeks before each meeting.

(iii) Search the European Binding Tariff Information ("EBTI") database (accessible via the European Commission's Taxation and Customs Union website) for new BTI rulings issued by any Member State classifying STS cranes or ASC systems — or substantially similar automated crane or gantry equipment — under headings 8426 or 8428. Search terms shall include, at a minimum, "ship-to-shore crane," "STS crane," "automated stacking crane," "ASC," "gantry crane," "container crane," "automated port equipment," and their equivalents in French and German.

(iv) Review the DG TAXUD website for any newly published consultations, guidance documents, explanatory notes, or classification opinions relating to headings 8426 or 8428.

Any potentially relevant finding shall be reported immediately to James Prentice and Garrett Simmons by email, with a copy to Sandra Tung. A brief monthly summary confirming that monitoring was performed and reporting any findings (or confirming a nil result) shall be maintained in the matter file.

B. AADE Communication Check

Responsible: Garrett Simmons, Associate (coordinating with Vournas & Theodorakis — Alexandros Vournas, Managing Partner, and Maria-Christina Georgiou, Associate)

Frequency: Monthly

Actions: On or about the first business day of each calendar month, Garrett Simmons shall contact Maria-Christina Georgiou at Vournas & Theodorakis to confirm the following:

(i) No communications have been received from AADE, the Directorate of Resolution of Disputes ("DED"), or the AADE Piraeus Regional Customs Office regarding the Additional Duty Assessment Notices (AADE/ADAN/2022/0073 and AADE/ADAN/2022/0074), the BTI application (BTI-GR-2022-003847), or any other matter relating to TSL's customs obligations.

(ii) No communications have been received from Meridian & Drakos Dikigiriko Grafeio (Panagiotis Drakos or Irini Konstantinou) regarding the standstill agreement, the assessment notices, or any related matter.

(iii) No standstill termination notice has been received from any party.

(iv) No enforcement action of any kind has been taken or threatened by AADE, including debt collection proceedings, liens on assets, seizures, or garnishments.

Vournas & Theodorakis shall provide a monthly negative confirmation by email to Garrett Simmons, copying Christy Bauer. If any communication is received, V&T shall immediately notify Calderwood & Harkness by telephone and email, and the reactivation protocols described in Section V shall be assessed.

C. Client Check-In

Responsible: Christy Bauer, Senior Associate

Frequency: Quarterly — in January, April, July, and October of each year

Actions: On or about the first business day of each quarter, Christy Bauer shall send a status update email to Elena Papadimitriou, Chief Financial Officer of Thalassa Shipping & Logistics SA, reporting on the following items:

(a) DG TAXUD consultation status — confirming whether any classification opinion, regulation, or guidance has been issued, and reporting on any relevant EBTI database or Customs Code Committee developments;

(b) AADE communications — confirming whether any communications have been received from AADE, the DED, or opposing counsel;

(c) Interest accrual update — providing the current estimated total of accrued statutory interest on the disputed additional duties, based on Garrett Simmons's quarterly interest calculation (see Section III.F below);

(d) Bank guarantee status — confirming that bank guarantee CMB-BG-2023-0291 remains in force and reporting any upcoming renewal dates or required actions;

(e) Insurance claim status — providing an update on the status of the coverage determination from Oceanos Underwriters SA, including any communications with Aether Insurance Brokers Ltd.

James Prentice shall be copied on all quarterly client updates. The email shall be concise and drafted for a non-legal audience, consistent with the format of prior client update letters. A copy of each quarterly update shall be filed in the document management system under the client correspondence sub-matter code.

D. Bank Guarantee Renewal Monitoring

Responsible: Garrett Simmons, Associate

Frequency: No later than sixty (60) days before the expiry date of bank guarantee CMB-BG-2023-0291

Actions: The following steps shall be taken to ensure timely renewal of the bank guarantee:

(i) Confirm the expiry date of bank guarantee CMB-BG-2023-0291 by reviewing the original guarantee instrument (certified copy on file in the Brussels office secure filing room).

(ii) Coordinate with Elena Papadimitriou (CFO, TSL) and Andreas Papathanasiou (Relationship Manager, Compass Maritime Bank SA) to initiate the renewal process in a timely manner.

(iii) Confirm that the guarantee will be renewed in the required amount of €5,000,000, or such greater or lesser amount as may be required under the terms of the standstill agreement or by agreement of the parties.

(iv) Notify Vournas & Theodorakis (for transmission to AADE) and Meridian & Drakos (as required under the standstill agreement) of the renewal, providing copies of the renewed guarantee instrument.

(v) File a copy of the renewed guarantee in the document management system and update the Brussels office secure filing room records as necessary.

If any difficulty arises in connection with the renewal — including credit facility constraints, bank reluctance, or TSL's inability or unwillingness to maintain the guarantee — the matter shall be immediately elevated to James Prentice for assessment.

E. Insurance Policy Renewal and Claim Monitoring

Responsible: James Prentice, Partner (coordinating with Fiona Hartwell, Aether Insurance Brokers Ltd.)

Frequency: Prior to each policy expiry and renewal date

Actions: The current insurance coverage is provided under Oceanos Underwriters SA Financial Lines Policy No. OCU-FIN-2021-GR-0487, with a policy period running from April 1, 2022 through March 31, 2023. The policy is subject to annual renewal, and the next renewal date is March 31, 2023 (the most recent renewal period), with subsequent annual renewals thereafter.

(i) Confirm that the policy has been renewed and that TSL's claim (filed October 15, 2022) remains duly notified under the renewed policy.

(ii) Confirm that the customs and excise duty disputes sublimit of €3,000,000 and the retention of €250,000 remain in force under the renewed policy terms.

(iii) Follow up on the pending coverage determination. As of the date of this memorandum, Oceanos Underwriters SA issued a reservation of rights letter on November 22, 2022, to which Calderwood & Harkness responded on behalf of TSL on December 12, 2022. The reservation of rights remains unresolved, and no definitive coverage determination — whether an acceptance, a partial acceptance, or a denial — has been issued. James Prentice shall coordinate with Fiona Hartwell at Aether Insurance Brokers Ltd. to press Oceanos for a definitive coverage position and to ensure that the claim remains properly reserved and that no procedural defenses are being asserted.

(iv) Report any material changes in policy terms, coverage limitations, or insurer communications to the engagement team and to Elena Papadimitriou as part of the quarterly client check-in.

F. Interest Accrual Tracking

Responsible: Garrett Simmons, Associate

Frequency: Quarterly

Actions: Garrett Simmons shall maintain and update a running interest calculation on the disputed additional duties, reflecting the continued accrual of statutory interest during the standstill period. The key parameters are as follows:

• Principal amount: €1,697,080 (total additional duties assessed under AADE/ADAN/2022/0073 and AADE/ADAN/2022/0074)

• Statutory interest rate: 0.73% per month (as established under the Greek Tax Procedure Code, Law 4174/2013)

• Monthly interest accrual: approximately €12,389 per month

• Accrued interest as of August 2022 (approximate base as of original assessment notices): €3,872,000

• Additional interest accrued during the period August 2022 through April 2023 (approximately 8 months): approximately €99,000

• Estimated total accrued interest as of April 10, 2023: approximately €3,970,000

The interest tracker shall be updated quarterly and maintained as a working document in the matter file. Each quarterly update shall be provided to Christy Bauer for inclusion in the quarterly client check-in. The interest calculations shall be reviewed by Vournas & Theodorakis on an annual basis to confirm consistency with Greek law and any regulatory changes affecting the statutory interest rate.

G. Standstill Compliance Monitoring

Responsible: Vournas & Theodorakis (Alexandros Vournas, primary; Maria-Christina Georgiou, backup)

Frequency: Ongoing (continuous)

Actions: Vournas & Theodorakis shall monitor, on a continuous basis, for any of the following events:

(i) Receipt of a written standstill termination notice from AADE or from Meridian & Drakos Dikigiriko Grafeio. Under the standstill agreement, either party may terminate upon sixty (60) days' written notice. Receipt of any such notice must be reported to Calderwood & Harkness immediately (within the same business day) by telephone and email.

(ii) Any indication that AADE has taken enforcement action in violation of the standstill, including but not limited to: initiation of debt collection proceedings, imposition of liens on TSL's assets, seizure of goods, garnishment of bank accounts, or any other compulsory collection measure directed at the assessed amounts or the bank guarantee.

(iii) Any communication from the Administrative Court of First Instance of Piraeus, the DED, or any other judicial or administrative body suggesting that the standstill is not being honored or that proceedings are being advanced.

Any event described above shall trigger immediate notification to Calderwood & Harkness and assessment of reactivation under Section V of this memorandum.

H. Statute of Limitations and Deadline Monitoring

Responsible: Vournas & Theodorakis (Maria-Christina Georgiou, Athens Bar No. 42917)

Frequency: Quarterly

Actions: Maria-Christina Georgiou shall confirm, on a quarterly basis, the following:

(i) No statutory deadlines are approaching under Greek customs law (Law 2960/2001), the Greek Tax Procedure Code (Law 4174/2013), or the Union Customs Code that would require action by TSL or its advisors.

(ii) The limitation period for TSL's administrative objections filed on November 30, 2022 is preserved and tolled during the standstill period. If any ambiguity arises as to the tolling effect of the standstill agreement under Greek law, V&T shall immediately report the issue to Calderwood & Harkness for joint analysis and potential protective action.

(iii) TSL's right to appeal any adverse DED decision or BTI ruling to the Administrative Court of First Instance of Piraeus remains preserved and has not been compromised by the passage of time or the standstill arrangement.

(iv) No limitation period applicable to TSL's indemnification claim against Peloros Customs Agency S.A. is at risk of expiring. The Customs Brokerage Agreement between TSL and Peloros contains a two-year contractual limitation period under Article 12.2 of the CBA, running from the date of the event giving rise to the claim. In addition, the Greek Civil Code (Article 937) provides a five-year tort limitation period. V&T shall monitor both periods and advise Calderwood & Harkness promptly if any protective filing or action is required to preserve TSL's indemnification rights.

Quarterly confirmations shall be provided in writing by email to Garrett Simmons and Christy Bauer, and filed in the matter management system.

IV. Tickler Dates

The following tickler dates are established to ensure proactive management of the matter during the dormant period. Each tickler shall be entered into the firm's calendaring and docketing system and assigned to the responsible team member(s).

All tickler dates shall be entered into the firm's central docketing system by Christy Bauer within five (5) business days of the date of this memorandum. Garrett Simmons shall confirm entry and verify accuracy.

V. Reactivation Triggers

The matter shall be immediately reactivated and the full engagement team notified upon the occurrence of any of the following events. Upon reactivation, James Prentice shall convene a team meeting within forty-eight (48) hours to assess the development, determine the required response, and establish a revised work plan.

1. DG TAXUD Classification Outcome. DG TAXUD issues a classification opinion, advisory opinion, or classification regulation under Article 57(4) of the Union Customs Code addressing the classification of STS gantry cranes and/or ASC systems under Combined Nomenclature headings 8426 or 8428, whether specifically in response to the AADE referral or in connection with a broader classification initiative affecting the same or substantially similar goods.

2. AADE BTI Ruling. AADE issues a Binding Tariff Information ruling in response to BTI Application No. BTI-GR-2022-003847, regardless of whether such ruling is consistent or inconsistent with TSL's classification position.

3. Standstill Termination. AADE or Meridian & Drakos Dikigiriko Grafeio issues a written standstill termination notice pursuant to the terms of the standstill agreement, triggering the sixty (60)-day termination period. Upon receipt of such notice, immediate action would be required to prepare for potential enforcement, assess the advisability of filing an appeal to the Administrative Court of First Instance of Piraeus, and evaluate the need for interim protective measures (including potential applications for suspension of enforcement pending appeal).

4. Oceanos Coverage Determination. Oceanos Underwriters SA issues a definitive coverage determination — whether an acceptance, a partial acceptance, or a denial — in response to TSL's claim filed October 15, 2022, or in connection with the reservation of rights issued November 22, 2022. A coverage denial or material limitation would require substantive analysis, potential dispute resolution under the policy, and assessment of the impact on TSL's overall financial exposure.

5. DED or AADE Communication. Any communication from AADE, the Directorate of Resolution of Disputes ("DED"), or the Administrative Court of First Instance of Piraeus requiring a substantive response from TSL or its advisors, including but not limited to: information requests, hearing notices, supplemental assessment notices, amended assessment notices, or requests for additional documentation or submissions in connection with the BTI application or the administrative objections.

6. Client Request. TSL requests reactivation of the matter for any reason, including but not limited to: the initiation or consideration of settlement discussions with AADE, a change in TSL's business strategy regarding the port equipment at issue, new factual developments affecting the classification or valuation arguments, or a decision by TSL's management or board to adopt a different strategic posture.

7. Financial Covenant Concern. Any material change in TSL's financial position that creates risk of breach of the Net Debt / EBITDA covenant (maximum ratio: 3.5×) under the Compass Maritime Bank SA revolving credit facility. In particular, the matter should be reactivated if TSL's Net Debt / EBITDA ratio approaches 3.2× or higher, reducing the available headroom below approximately €13.7 million and making the potential crystallization of the full AADE assessment a material factor in covenant compliance.

8. Peloros Development. Receipt of any response from Peloros Customs Agency S.A. to the demand and preservation letter of December 15, 2022, including but not limited to: a substantive response to the indemnification demand, provision of information regarding Peloros's professional indemnity insurance coverage, assertion of defenses or counterclaims, notice of limitation period issues, or any communication from Peloros's legal advisors.

9. Legislative or Regulatory Change. Any amendment, repeal, or material modification of the Union Customs Code (Regulation (EU) No. 952/2013), the Combined Nomenclature (Commission Implementing Regulation (EU) 2022/1998 or successors), Greek customs law (Law 2960/2001), the Greek Tax Procedure Code (Law 4174/2013), or any related implementing or delegated regulation that materially affects the classification or valuation issues in dispute, the penalty regime applicable to TSL's case, the administrative objection or judicial appeal process, or the standstill arrangement.

10. Related EU Litigation. The filing or resolution of any preliminary reference to the Court of Justice of the European Union ("CJEU") under Article 267 TFEU, or any judgment of the CJEU or the General Court, addressing the classification of automated gantry cranes, STS cranes, ASC systems, or functionally similar automated port handling equipment under Combined Nomenclature headings 8426 or 8428. This includes references originating from the courts of any EU Member State and judgments in infringement proceedings brought by the Commission under Articles 258–260 TFEU relating to customs classification practices.

The foregoing list of reactivation triggers is intended to be comprehensive but is not exhaustive. Any development that, in the professional judgment of any member of the engagement team, materially affects TSL's legal position, financial exposure, or strategic options shall be treated as a potential reactivation trigger and reported to James Prentice for assessment.

VI. Filing and Records

All matter files are maintained in the Calderwood & Harkness LLP document management system under Matter No. C&H-2022-ITS-04781. The matter is organized into the following sub-matter codes, corresponding to the principal work streams:

• 04781-01 — Classification (CN 8426 vs. CN 8428)

• 04781-02 — Customs Valuation (technology license fees, Nereus procurement fees, commissioning services)

• 04781-03 — BTI Application and DG TAXUD Consultation

• 04781-04 — Insurance Claim (Oceanos Underwriters SA)

• 04781-05 — Lender Notification and Covenant Monitoring (Compass Maritime Bank SA)

• 04781-06 — Peloros Customs Agency Indemnification

• 04781-07 — Administrative Objections (DED proceedings)

• 04781-08 — DG TAXUD Monitoring and Regulatory Developments

• 04781-09 — Client Correspondence

• 04781-10 — Internal Administration (engagement letter, retention letters, billing, dormancy)

Physical files containing originals of executed documents are stored in the Calderwood & Harkness Brussels office secure filing room, Room B-412. The following original documents are maintained in the physical file:

• Engagement letter (executed September 22, 2022)

• Local counsel retention letter — Vournas & Theodorakis (countersigned October 2, 2022)

• Expert retention letter — Argonaut Trade Consulting GmbH (countersigned October 10, 2022)

• Expert retention letter — Kestrel & Palladian LLP (countersigned October 11, 2022)

• Standstill agreement letter (countersigned March 1, 2023)

• Bank guarantee CMB-BG-2023-0291 (original delivered to AADE; certified copy maintained in file)

• BTI Application BTI-GR-2022-003847 (filed copy bearing AADE receipt stamp dated November 15, 2022)

• Administrative objection to AADE/ADAN/2022/0073 — Classification (filed copy)

• Administrative objection to AADE/ADAN/2022/0074 — Valuation (filed copy)

Vournas & Theodorakis maintains parallel files at its Athens offices for all Greek-language originals, filings, and correspondence with AADE, the DED, and the Administrative Court. V&T's files include originals of all documents filed with or received from Greek administrative and judicial authorities, as well as original Greek-language correspondence with Meridian & Drakos.

A comprehensive electronic document index is maintained by Christy Bauer and was last updated as of April 10, 2023. The index shall be updated upon any filing or receipt of new documents during the dormancy period, and shall be comprehensively reviewed and updated upon reactivation.

VII. Billing During Dormancy

Billing on this matter is expected to be minimal during the dormant period. The primary billable activities will consist of the monitoring protocols established in Section III of this memorandum — including DG TAXUD database checks, AADE communication confirmations with local counsel, interest accrual calculations, and quarterly client status updates.

The estimated monthly dormancy costs are approximately $1,500 to $3,000 per month, reflecting one to three hours of associate time per month. The anticipated billing breakdown is as follows:

• Christy Bauer (Senior Associate, current rate: $895/hour) — approximately 1–2 hours per month for DG TAXUD monitoring, quarterly client check-ins, and document index maintenance.

• Garrett Simmons (Associate, current rate: $775/hour) — approximately 0.5–1 hour per month for AADE communication checks, interest accrual calculations, and bank guarantee monitoring.

Partner time is expected to be limited during the dormant period. James Prentice ($1,475/hour) is anticipated to spend time on the matter only for quarterly review of client updates, insurance claim follow-up and coordination with Aether Insurance Brokers Ltd., and assessment of any potential reactivation triggers. Sandra Tung ($1,475/hour) will review billing monthly to confirm that activity levels are consistent with dormancy status and to flag any unexpected increases in billing that may indicate unauthorized reactivation or scope expansion.

Local counsel fees from Vournas & Theodorakis during the dormancy period are estimated at approximately €500 to €1,000 per month, covering standstill compliance monitoring, monthly AADE communication checks, quarterly statute of limitations confirmations, and associated administrative support.

No expert fees are anticipated during the dormancy period. Dr. Lukas Brenner (Argonaut Trade Consulting GmbH) and Spyros Makris (Kestrel & Palladian LLP) have been advised that their work is suspended pending further notice. Expert retention agreements remain in effect, and both experts have confirmed their availability for reactivation. Expert fees would be incurred only if DG TAXUD requests additional technical input in connection with its consultation, which is not expected but cannot be excluded.

Billing shall continue on the standard monthly invoice cycle. If billable activity in a given month is de minimis — for example, limited to a single monitoring check with no substantive findings — invoices may be consolidated and issued on a quarterly basis at Sandra Tung's discretion. All invoices shall be clearly marked to indicate that the matter is in dormant status.

VIII. Key Contact Information During Dormancy

The following table sets forth the key contacts for the matter during the dormant period. All team members should ensure that their contact information remains current in the firm's directory and that any extended absences or departures are communicated in advance to permit reassignment of monitoring responsibilities.

This memorandum constitutes the firm's internal record of the dormancy determination and shall govern the management of Matter No. C&H-2022-ITS-04781 until the matter is reactivated pursuant to Section V. All members of the engagement team are responsible for fulfilling their assigned monitoring obligations as set forth herein.

Please contact either of the undersigned with any questions or concerns.

CALDERWOOD & HARKNESS LLP

By: ________

Christy Bauer Senior Associate, intellectual Property Group Calderwood & Harkness LLP

By: ________

Garrett Simmons Associate, Tax Group Calderwood & Harkness LLP

cc: Matter File — C&H-2022-ITS-04781

Item	Status
Client	Thalassa Shipping & Logistics SA ("TSL") (EORI: GR094827361000; AFM: 094827361)
Matter No.	C&H-2022-ITS-04781
Responsible Partner	James Prentice
Billing Partner	Sandra Tung
Lead Associate	Christy Bauer (Intellectual Property Group)
Working Associate	Garrett Simmons (Tax Group)
Local Counsel	Vournas & Theodorakis (Alexandros Vournas, Managing Partner; Maria-Christina Georgiou, Associate)
Opposing Counsel	Meridian & Drakos Dikigiriko Grafeio (Panagiotis Drakos, Senior Partner; Irini Konstantinou, Associate)
AADE Assessment (mid-case estimate)	Approximately €8,818,620, comprising: duties €1,697,080 + VAT €2,740,416 + penalties €509,124 + interest €3,872,000
AADE Assessment (high-end estimate)	Approximately €14.7 million, including escalated penalties up to €5,091,240 and compounding interest at the statutory rate
Classification Dispute	20 units (12 STS gantry cranes + 8 ASC systems); TSL classification: CN 8426 41 00 (STS cranes) / CN 8426 19 00 (ASC systems) — 0% duty; AADE classification: CN 8428 90 90 (ASC systems) — 2.2% duty; additional duty assessed: €1,478,400
Valuation Dispute	€9,940,000 adjustment to declared customs value, comprising: €4,900,000 (technology license fees) + €2,940,000 (Nereus procurement fees) + €2,100,000 (commissioning services); additional duty assessed: €218,680
BTI Application	BTI-GR-2022-003847; filed November 15, 2022; referred to DG TAXUD February 7, 2023; pending DG TAXUD consultation
Administrative Objections	Filed November 30, 2022 (ADAN/2022/0073 — Classification; ADAN/2022/0074 — Valuation); DED proceedings held in abeyance pursuant to standstill
Standstill Agreement	In effect since March 1, 2023; terminable on 60 days' written notice or upon resolution of DG TAXUD consultation / issuance of BTI ruling
Bank Guarantee	CMB-BG-2023-0291; €5,000,000; issued March 10, 2023 by Compass Maritime Bank SA
Insurance Claim	Filed October 15, 2022 via Aether Insurance Brokers Ltd.; Oceanos Underwriters SA Financial Lines Policy No. OCU-FIN-2021-GR-0487; customs & excise duty disputes sublimit: €3,000,000; retention: €250,000; reservation of rights issued November 22, 2022; C&H response sent December 12, 2022; definitive coverage determination still pending
Lender Notification	Material litigation disclosure to Compass Maritime Bank SA — sent October 3, 2022
Peloros Indemnification	Demand and preservation letter sent to Peloros Customs Agency S.A. on December 15, 2022; no response received as of the date of this memorandum
Financial Covenant Status	Net Debt / EBITDA at 2.9× (covenant maximum: 3.5×); headroom approximately €27.4 million (based on updated Q4 2022 projections); all modeled scenarios — including full assessment payment — remain within covenant compliance
Date	Action	Responsible
July 1, 2023	First quarterly client check-in during dormancy (Q3 2023). Status email to Elena Papadimitriou (CFO, TSL) covering: DG TAXUD consultation status, AADE communications, interest accrual update, bank guarantee status, and insurance claim status. Copy James Prentice on all communications.	Christy Bauer
September 1, 2023	Assess whether to make proactive inquiry to DG TAXUD — either through AADE (via V&T) or directly through the firm's Brussels office — requesting a status update on the BTI consultation referral. Determine whether a direct communication from C&H's Brussels office to the relevant DG TAXUD unit would be appropriate and strategically advisable.	Christy Bauer / James Prentice
October 1, 2023	Second quarterly client check-in during dormancy (Q4 2023). Status email to Elena Papadimitriou in the same format as the July check-in.	Christy Bauer

CALDERWOOD & HARKNESS LLP
Brussels | London | New York | Singapore | Athens
CONFIDENTIAL — INTERNAL
MEMORANDUM
TO: James Prentice, Partner, International Trade & Sanctions Group Sandra Tung, Partner, International Trade & Sanctions Group
FROM: Christy Bauer, Senior Associate, intellectual Property Group Garrett Simmons, Associate, Tax Group
DATE: April 10, 2023
RE: Matter Dormancy Status — C&H-2022-ITS-04781 (Thalassa Shipping & Logistics SA — Customs Classification and Valuation Dispute)
This memorandum recommends and documents the placement of the above-referenced matter into dormant status. It summarizes the basis for dormancy, sets forth the current posture of the matter, establishes monitoring protocols to be observed during the dormant period, identifies tickler dates for proactive review, and defines the triggers under which the matter shall be reactivated. The memorandum is intended to serve as the definitive internal record of the matter's status as of the date hereof and to ensure continuity of service in the event of future reactivation.
I. Basis for Dormancy
Effective as of the date of this memorandum, Matter No. C&H-2022-ITS-04781 is being placed in dormant status. This determination is based on the confluence of four factors, each of which is described in detail below. In combination, these factors establish that no productive substantive work can be advanced at this time, that the client's rights and positions are fully preserved through existing agreements and filings, and that the matter is in a posture that warrants monitoring rather than active engagement.
A. BTI Application Pending at DG TAXUD
The central driver of the dormancy determination is the pendency of the Binding Tariff Information application before the European Commission's Directorate-General for Taxation and Customs Union ("DG TAXUD"), for which no timeline for resolution has been provided and over which neither the firm nor the client has meaningful procedural control.
BTI Application No. BTI-GR-2022-003847 was filed with the Independent Authority for Public Revenue of the Hellenic Republic ("AADE") on November 15, 2022, requesting a binding classification determination for the twenty units of automated port handling equipment at issue in this matter — specifically, twelve ship-to-shore ("STS") gantry cranes and eight automated stacking crane ("ASC") systems imported by Thalassa Shipping & Logistics SA ("TSL") through the Port of Piraeus between 2018 and 2021.
On February 7, 2023, AADE referred the BTI application to DG TAXUD for consultation, pursuant to Article 34(10) of the Union Customs Code (Regulation (EU) No. 952/2013) ("UCC"). The referral was triggered by the existence of divergent BTI rulings issued by other Member State customs authorities addressing substantially similar equipment. Specifically, the Netherlands customs authority issued BTI Ruling No. NL-BTI-2021-01234, classifying comparable STS cranes and ASC systems under Combined Nomenclature headings 8426 41 00 (for STS cranes — self-propelled, on wheels) and 8426 19 00 (for ASC systems — other overhead travelling cranes), both of which carry a conventional duty rate of 0%. In contrast, the German customs authority issued BTI Ruling No. DE-BTI-2020-05678, classifying ASC systems under CN heading 8428 90 90 (other lifting, handling, loading, or unloading machinery — other), which carries a conventional duty rate of 2.2%. The existence of these conflicting rulings required AADE to seek a uniform classification position from DG TAXUD before issuing its own BTI determination, in accordance with the procedural obligations set forth in the UCC Implementing Regulation.
As of the date of this memorandum, DG TAXUD has not provided any indication of the expected timeline for its consultation. No acknowledgment of the referral has been issued to TSL or its advisors, and AADE has confirmed only that the matter is "under consideration at the Commission level." Based on our review of historical precedent involving DG TAXUD classification consultations — including consultations on the classification of automated guided vehicles (2017–2019), remotely operated container spreaders (2019–2021), and semi-automated reach stackers (2020–2022) — the typical duration of such consultations ranges from twelve to twenty-four months. In certain cases involving complex technical assessments or the need for input from the Customs Code Committee (Section for Tariff and Statistical Nomenclature — formerly the Nomenclature Committee), consultations have extended beyond twenty-four months.
Accordingly, the estimated resolution window for the DG TAXUD consultation is Q1 2024 through Q1 2025, and potentially later. Until DG TAXUD provides its consultation opinion or guidance, AADE is unlikely to issue a BTI ruling, and the classification dispute — which constitutes the central legal question in this matter and drives the vast majority of the assessed additional duties — will remain unresolved.
B. Standstill Agreement in Effect
The enforcement posture of this matter is currently governed by a standstill agreement that suspends all collection and enforcement activity by AADE for the duration of the DG TAXUD consultation, thereby eliminating the immediate litigation pressure that would otherwise necessitate active engagement.
The standstill agreement between TSL and AADE was executed on March 1, 2023. The agreement was negotiated through an exchange of correspondence between Calderwood & Harkness LLP (on behalf of TSL, in coordination with local counsel Vournas & Theodorakis) and Meridian & Drakos Dikigiriko Grafeio (as external legal advisors to AADE). The standstill agreement was countersigned by Panagiotis Drakos, Senior Partner of Meridian & Drakos, on behalf of AADE's legal representation, and by Aikaterini Vlachopoulou, Chief Customs Auditor of the AADE Piraeus Regional Customs Office, on behalf of AADE in its administrative capacity.
The key terms of the standstill agreement are as follows:
(a) Enforcement Suspension. AADE agrees that it will not enforce, execute upon, or take any collection action with respect to Additional Duty Assessment Notice No. AADE/ADAN/2022/0073 (addressing the classification dispute) or Additional Duty Assessment Notice No. AADE/ADAN/2022/0074 (addressing the valuation dispute) for the duration of the standstill period.
(b) Security. TSL has posted a bank guarantee in the amount of €5,000,000 as security for the assessed amounts during the standstill period. The guarantee was issued by Compass Maritime Bank SA under Guarantee No. CMB-BG-2023-0291, dated March 10, 2023, and is payable on first demand to AADE in the event of a termination of the standstill followed by a final, non-appealable determination in AADE's favor.
(c) Administrative Proceedings in Abeyance. The proceedings before the Directorate of Resolution of Disputes ("DED") on TSL's administrative objections (filed November 30, 2022) are held in abeyance for the duration of the standstill period. No hearings will be scheduled, and no further submissions will be required, unless the standstill is terminated.
(d) Duration and Termination. The standstill continues in effect until the earliest of: (i) DG TAXUD issues a consultation opinion or classification guidance addressing the classification of the equipment at issue; (ii) AADE issues a BTI ruling in response to Application No. BTI-GR-2022-003847; or (iii) either party terminates the standstill upon sixty (60) days' written notice to the other party.
(e) Interest Accrual. Statutory interest continues to accrue on the disputed additional duties at the rate of 0.73% per month during the standstill period. The agreement expressly provides that the standstill does not constitute a waiver of AADE's right to collect accrued interest in the event of a final determination in its favor.
(f) Preservation of Rights. Both parties preserve all rights, claims, and defenses, including TSL's right to appeal any adverse DED decision or BTI ruling to the Administrative Court of First Instance of Piraeus.
The standstill agreement provides TSL with the procedural breathing room necessary to await the outcome of the DG TAXUD consultation without the risk of enforcement action. The bank guarantee, while representing a significant commitment of TSL's credit capacity, secures AADE's position and was a necessary condition for AADE's agreement to the standstill.
C. All Core Work Product Delivered
All substantive work product associated with the engagement through the current phase has been completed and delivered. The matter was structured in two phases: Phase 1 (assessment, analysis, and strategy development, covering the period from engagement through the filing of the BTI application and administrative objections) and Phase 2 (BTI prosecution, standstill negotiation, and related third-party notifications). Both phases are complete. The full inventory of deliverables is as follows:
Phase 1 — Assessment, Analysis, and Strategy:
1. Preliminary Case Assessment Memorandum — delivered October 14, 2022
2. Classification Analysis Memorandum — delivered November 8, 2022
3. Customs Valuation Analysis Memorandum — delivered November 10, 2022
4. Nereus Related-Party Analysis Memorandum — delivered November 18, 2022
5. Technology License Agreement Analysis Memorandum — delivered November 22, 2022
6. Penalty Exposure & Mitigation Memorandum — delivered November 25, 2022
7. Insurance Coverage Analysis Memorandum — delivered December 2, 2022
8. Financial Covenant Impact Memorandum — delivered December 5, 2022
9. Comparative BTI Rulings Analysis Memorandum — delivered December 8, 2022
10. Peloros Customs Agency Indemnification Rights Memorandum — delivered December 12, 2022
Phase 2 — Filings, Negotiations, and Third-Party Notifications:
11. BTI Application (including Draft Application, Technical Annex, and Legal Argument Annex) — filed with AADE on November 15, 2022
12. Administrative Objection to AADE/ADAN/2022/0073 (Classification) — filed with DED on November 30, 2022
13. Administrative Objection to AADE/ADAN/2022/0074 (Valuation) — filed with DED on November 30, 2022
14. Standstill Agreement Letter — executed March 1, 2023
15. Supplemental Submission to DG TAXUD — filed March 15, 2023
16. Response to AADE Information Request — submitted January 18, 2023
17. Client Update Letters — issued October 2022, November 2022, February 2023, and March 2023
18. Letter to Compass Maritime Bank SA — material litigation disclosure — sent October 3, 2022
19. Notice of Claim to Oceanos Underwriters SA (submitted via Aether Insurance Brokers Ltd.) — sent October 15, 2022
20. Response to Oceanos Reservation of Rights Letter — sent December 12, 2022
21. Demand and Preservation Letter to Peloros Customs Agency S.A. — sent December 15, 2022
22. Document Preservation Notice to TSL — sent October 20, 2022
23. Expert Retention Letters — Argonaut Trade Consulting GmbH (sent October 5, 2022; countersigned October 10, 2022) and Kestrel & Palladian LLP (sent October 5, 2022; countersigned October 11, 2022)
24. Local Counsel Retention Letter — Vournas & Theodorakis (sent September 28, 2022; countersigned October 2, 2022)
All deliverables have been indexed, filed in the document management system, and confirmed as received by the intended recipients. No outstanding deliverables remain.
D. No Active Substantive Tasks Pending
As of the date of this memorandum, there are no outstanding filings, deadlines, or substantive work requests on this matter. The matter is in a holding posture, awaiting external events — principally the outcome of the DG TAXUD classification consultation and any communications that AADE may issue in connection with the BTI application, the standstill, or the administrative objections.
All expert reports have been either finalized or brought to a stage of completion sufficient for the current phase of the matter. The classification expert report prepared by Dr. Lukas Brenner of Argonaut Trade Consulting GmbH (Munich) — addressing the technical characteristics and functional design of the STS cranes and ASC systems and their proper classification under the Combined Nomenclature — was finalized in November 2022 and submitted as the Technical Annex to the BTI Application. The customs valuation expert report prepared by Spyros Makris of Kestrel & Palladian LLP (London) — addressing the proper treatment of the technology license fees, Nereus procurement fees, and commissioning services under Articles 70–74 of the UCC and the related implementing provisions — is in final draft form sufficient for the current stage, with minor revisions to be made if and when the matter reactivates for DED proceedings or judicial appeal.
No action by the engagement team will materially advance the matter's resolution until one or more of the reactivation triggers described in Section V of this memorandum occurs.
II. Summary of Matter Status at Dormancy
The following table provides a consolidated summary of the key facts, parties, and current posture of the matter as of the date of dormancy:
The foregoing summary reflects the matter's posture as of April 10, 2023. All figures are based on the most recent information available and are subject to update upon reactivation.
III. Dormancy Monitoring Protocols
Although the matter is being placed in dormant status, ongoing monitoring is essential to protect TSL's legal rights, preserve the standstill, track accruing interest exposure, and ensure that any reactivation trigger is promptly identified and acted upon. The following monitoring protocols shall remain in effect for the duration of the dormant period. Each protocol identifies the responsible team member, the frequency of the monitoring activity, and the specific actions to be taken.
A. DG TAXUD Monitoring
Responsible: Christy Bauer, Senior Associate
Frequency: Monthly
Actions: The following monitoring activities shall be performed on or about the first business day of each calendar month:
(i) Review the Official Journal of the European Union for any classification regulations published by the European Commission under Article 57(4) of the UCC addressing the classification of STS gantry cranes, ASC systems, automated port handling equipment, or related goods under Combined Nomenclature headings 8426 or 8428.
(ii) Monitor the meeting agendas and published minutes of the Customs Code Committee, Section for Tariff and Statistical Nomenclature, for any agenda items or discussion points relating to the classification of lifting, handling, or loading equipment, including STS cranes and ASC systems. Meeting agendas are typically published on the European Commission's comitology register approximately two weeks before each meeting.
(iii) Search the European Binding Tariff Information ("EBTI") database (accessible via the European Commission's Taxation and Customs Union website) for new BTI rulings issued by any Member State classifying STS cranes or ASC systems — or substantially similar automated crane or gantry equipment — under headings 8426 or 8428. Search terms shall include, at a minimum, "ship-to-shore crane," "STS crane," "automated stacking crane," "ASC," "gantry crane," "container crane," "automated port equipment," and their equivalents in French and German.
(iv) Review the DG TAXUD website for any newly published consultations, guidance documents, explanatory notes, or classification opinions relating to headings 8426 or 8428.
Any potentially relevant finding shall be reported immediately to James Prentice and Garrett Simmons by email, with a copy to Sandra Tung. A brief monthly summary confirming that monitoring was performed and reporting any findings (or confirming a nil result) shall be maintained in the matter file.
B. AADE Communication Check
Responsible: Garrett Simmons, Associate (coordinating with Vournas & Theodorakis — Alexandros Vournas, Managing Partner, and Maria-Christina Georgiou, Associate)
Frequency: Monthly
Actions: On or about the first business day of each calendar month, Garrett Simmons shall contact Maria-Christina Georgiou at Vournas & Theodorakis to confirm the following:
(i) No communications have been received from AADE, the Directorate of Resolution of Disputes ("DED"), or the AADE Piraeus Regional Customs Office regarding the Additional Duty Assessment Notices (AADE/ADAN/2022/0073 and AADE/ADAN/2022/0074), the BTI application (BTI-GR-2022-003847), or any other matter relating to TSL's customs obligations.
(ii) No communications have been received from Meridian & Drakos Dikigiriko Grafeio (Panagiotis Drakos or Irini Konstantinou) regarding the standstill agreement, the assessment notices, or any related matter.
(iii) No standstill termination notice has been received from any party.
(iv) No enforcement action of any kind has been taken or threatened by AADE, including debt collection proceedings, liens on assets, seizures, or garnishments.
Vournas & Theodorakis shall provide a monthly negative confirmation by email to Garrett Simmons, copying Christy Bauer. If any communication is received, V&T shall immediately notify Calderwood & Harkness by telephone and email, and the reactivation protocols described in Section V shall be assessed.
C. Client Check-In
Responsible: Christy Bauer, Senior Associate
Frequency: Quarterly — in January, April, July, and October of each year
Actions: On or about the first business day of each quarter, Christy Bauer shall send a status update email to Elena Papadimitriou, Chief Financial Officer of Thalassa Shipping & Logistics SA, reporting on the following items:
(a) DG TAXUD consultation status — confirming whether any classification opinion, regulation, or guidance has been issued, and reporting on any relevant EBTI database or Customs Code Committee developments;
(b) AADE communications — confirming whether any communications have been received from AADE, the DED, or opposing counsel;
(c) Interest accrual update — providing the current estimated total of accrued statutory interest on the disputed additional duties, based on Garrett Simmons's quarterly interest calculation (see Section III.F below);
(d) Bank guarantee status — confirming that bank guarantee CMB-BG-2023-0291 remains in force and reporting any upcoming renewal dates or required actions;
(e) Insurance claim status — providing an update on the status of the coverage determination from Oceanos Underwriters SA, including any communications with Aether Insurance Brokers Ltd.
James Prentice shall be copied on all quarterly client updates. The email shall be concise and drafted for a non-legal audience, consistent with the format of prior client update letters. A copy of each quarterly update shall be filed in the document management system under the client correspondence sub-matter code.
D. Bank Guarantee Renewal Monitoring
Responsible: Garrett Simmons, Associate
Frequency: No later than sixty (60) days before the expiry date of bank guarantee CMB-BG-2023-0291
Actions: The following steps shall be taken to ensure timely renewal of the bank guarantee:
(i) Confirm the expiry date of bank guarantee CMB-BG-2023-0291 by reviewing the original guarantee instrument (certified copy on file in the Brussels office secure filing room).
(ii) Coordinate with Elena Papadimitriou (CFO, TSL) and Andreas Papathanasiou (Relationship Manager, Compass Maritime Bank SA) to initiate the renewal process in a timely manner.
(iii) Confirm that the guarantee will be renewed in the required amount of €5,000,000, or such greater or lesser amount as may be required under the terms of the standstill agreement or by agreement of the parties.
(iv) Notify Vournas & Theodorakis (for transmission to AADE) and Meridian & Drakos (as required under the standstill agreement) of the renewal, providing copies of the renewed guarantee instrument.
(v) File a copy of the renewed guarantee in the document management system and update the Brussels office secure filing room records as necessary.
If any difficulty arises in connection with the renewal — including credit facility constraints, bank reluctance, or TSL's inability or unwillingness to maintain the guarantee — the matter shall be immediately elevated to James Prentice for assessment.
E. Insurance Policy Renewal and Claim Monitoring
Responsible: James Prentice, Partner (coordinating with Fiona Hartwell, Aether Insurance Brokers Ltd.)
Frequency: Prior to each policy expiry and renewal date
Actions: The current insurance coverage is provided under Oceanos Underwriters SA Financial Lines Policy No. OCU-FIN-2021-GR-0487, with a policy period running from April 1, 2022 through March 31, 2023. The policy is subject to annual renewal, and the next renewal date is March 31, 2023 (the most recent renewal period), with subsequent annual renewals thereafter.
(i) Confirm that the policy has been renewed and that TSL's claim (filed October 15, 2022) remains duly notified under the renewed policy.
(ii) Confirm that the customs and excise duty disputes sublimit of €3,000,000 and the retention of €250,000 remain in force under the renewed policy terms.
(iii) Follow up on the pending coverage determination. As of the date of this memorandum, Oceanos Underwriters SA issued a reservation of rights letter on November 22, 2022, to which Calderwood & Harkness responded on behalf of TSL on December 12, 2022. The reservation of rights remains unresolved, and no definitive coverage determination — whether an acceptance, a partial acceptance, or a denial — has been issued. James Prentice shall coordinate with Fiona Hartwell at Aether Insurance Brokers Ltd. to press Oceanos for a definitive coverage position and to ensure that the claim remains properly reserved and that no procedural defenses are being asserted.
(iv) Report any material changes in policy terms, coverage limitations, or insurer communications to the engagement team and to Elena Papadimitriou as part of the quarterly client check-in.
F. Interest Accrual Tracking
Responsible: Garrett Simmons, Associate
Frequency: Quarterly
Actions: Garrett Simmons shall maintain and update a running interest calculation on the disputed additional duties, reflecting the continued accrual of statutory interest during the standstill period. The key parameters are as follows:
• Principal amount: €1,697,080 (total additional duties assessed under AADE/ADAN/2022/0073 and AADE/ADAN/2022/0074)
• Statutory interest rate: 0.73% per month (as established under the Greek Tax Procedure Code, Law 4174/2013)
• Monthly interest accrual: approximately €12,389 per month
• Accrued interest as of August 2022 (approximate base as of original assessment notices): €3,872,000
• Additional interest accrued during the period August 2022 through April 2023 (approximately 8 months): approximately €99,000
• Estimated total accrued interest as of April 10, 2023: approximately €3,970,000
The interest tracker shall be updated quarterly and maintained as a working document in the matter file. Each quarterly update shall be provided to Christy Bauer for inclusion in the quarterly client check-in. The interest calculations shall be reviewed by Vournas & Theodorakis on an annual basis to confirm consistency with Greek law and any regulatory changes affecting the statutory interest rate.
G. Standstill Compliance Monitoring
Responsible: Vournas & Theodorakis (Alexandros Vournas, primary; Maria-Christina Georgiou, backup)
Frequency: Ongoing (continuous)
Actions: Vournas & Theodorakis shall monitor, on a continuous basis, for any of the following events:
(i) Receipt of a written standstill termination notice from AADE or from Meridian & Drakos Dikigiriko Grafeio. Under the standstill agreement, either party may terminate upon sixty (60) days' written notice. Receipt of any such notice must be reported to Calderwood & Harkness immediately (within the same business day) by telephone and email.
(ii) Any indication that AADE has taken enforcement action in violation of the standstill, including but not limited to: initiation of debt collection proceedings, imposition of liens on TSL's assets, seizure of goods, garnishment of bank accounts, or any other compulsory collection measure directed at the assessed amounts or the bank guarantee.
(iii) Any communication from the Administrative Court of First Instance of Piraeus, the DED, or any other judicial or administrative body suggesting that the standstill is not being honored or that proceedings are being advanced.
Any event described above shall trigger immediate notification to Calderwood & Harkness and assessment of reactivation under Section V of this memorandum.
H. Statute of Limitations and Deadline Monitoring
Responsible: Vournas & Theodorakis (Maria-Christina Georgiou, Athens Bar No. 42917)
Frequency: Quarterly
Actions: Maria-Christina Georgiou shall confirm, on a quarterly basis, the following:
(i) No statutory deadlines are approaching under Greek customs law (Law 2960/2001), the Greek Tax Procedure Code (Law 4174/2013), or the Union Customs Code that would require action by TSL or its advisors.
(ii) The limitation period for TSL's administrative objections filed on November 30, 2022 is preserved and tolled during the standstill period. If any ambiguity arises as to the tolling effect of the standstill agreement under Greek law, V&T shall immediately report the issue to Calderwood & Harkness for joint analysis and potential protective action.
(iii) TSL's right to appeal any adverse DED decision or BTI ruling to the Administrative Court of First Instance of Piraeus remains preserved and has not been compromised by the passage of time or the standstill arrangement.
(iv) No limitation period applicable to TSL's indemnification claim against Peloros Customs Agency S.A. is at risk of expiring. The Customs Brokerage Agreement between TSL and Peloros contains a two-year contractual limitation period under Article 12.2 of the CBA, running from the date of the event giving rise to the claim. In addition, the Greek Civil Code (Article 937) provides a five-year tort limitation period. V&T shall monitor both periods and advise Calderwood & Harkness promptly if any protective filing or action is required to preserve TSL's indemnification rights.
Quarterly confirmations shall be provided in writing by email to Garrett Simmons and Christy Bauer, and filed in the matter management system.
IV. Tickler Dates
The following tickler dates are established to ensure proactive management of the matter during the dormant period. Each tickler shall be entered into the firm's calendaring and docketing system and assigned to the responsible team member(s).
All tickler dates shall be entered into the firm's central docketing system by Christy Bauer within five (5) business days of the date of this memorandum. Garrett Simmons shall confirm entry and verify accuracy.
V. Reactivation Triggers
The matter shall be immediately reactivated and the full engagement team notified upon the occurrence of any of the following events. Upon reactivation, James Prentice shall convene a team meeting within forty-eight (48) hours to assess the development, determine the required response, and establish a revised work plan.
1. DG TAXUD Classification Outcome. DG TAXUD issues a classification opinion, advisory opinion, or classification regulation under Article 57(4) of the Union Customs Code addressing the classification of STS gantry cranes and/or ASC systems under Combined Nomenclature headings 8426 or 8428, whether specifically in response to the AADE referral or in connection with a broader classification initiative affecting the same or substantially similar goods.
2. AADE BTI Ruling. AADE issues a Binding Tariff Information ruling in response to BTI Application No. BTI-GR-2022-003847, regardless of whether such ruling is consistent or inconsistent with TSL's classification position.
3. Standstill Termination. AADE or Meridian & Drakos Dikigiriko Grafeio issues a written standstill termination notice pursuant to the terms of the standstill agreement, triggering the sixty (60)-day termination period. Upon receipt of such notice, immediate action would be required to prepare for potential enforcement, assess the advisability of filing an appeal to the Administrative Court of First Instance of Piraeus, and evaluate the need for interim protective measures (including potential applications for suspension of enforcement pending appeal).
4. Oceanos Coverage Determination. Oceanos Underwriters SA issues a definitive coverage determination — whether an acceptance, a partial acceptance, or a denial — in response to TSL's claim filed October 15, 2022, or in connection with the reservation of rights issued November 22, 2022. A coverage denial or material limitation would require substantive analysis, potential dispute resolution under the policy, and assessment of the impact on TSL's overall financial exposure.
5. DED or AADE Communication. Any communication from AADE, the Directorate of Resolution of Disputes ("DED"), or the Administrative Court of First Instance of Piraeus requiring a substantive response from TSL or its advisors, including but not limited to: information requests, hearing notices, supplemental assessment notices, amended assessment notices, or requests for additional documentation or submissions in connection with the BTI application or the administrative objections.
6. Client Request. TSL requests reactivation of the matter for any reason, including but not limited to: the initiation or consideration of settlement discussions with AADE, a change in TSL's business strategy regarding the port equipment at issue, new factual developments affecting the classification or valuation arguments, or a decision by TSL's management or board to adopt a different strategic posture.
7. Financial Covenant Concern. Any material change in TSL's financial position that creates risk of breach of the Net Debt / EBITDA covenant (maximum ratio: 3.5×) under the Compass Maritime Bank SA revolving credit facility. In particular, the matter should be reactivated if TSL's Net Debt / EBITDA ratio approaches 3.2× or higher, reducing the available headroom below approximately €13.7 million and making the potential crystallization of the full AADE assessment a material factor in covenant compliance.
8. Peloros Development. Receipt of any response from Peloros Customs Agency S.A. to the demand and preservation letter of December 15, 2022, including but not limited to: a substantive response to the indemnification demand, provision of information regarding Peloros's professional indemnity insurance coverage, assertion of defenses or counterclaims, notice of limitation period issues, or any communication from Peloros's legal advisors.
9. Legislative or Regulatory Change. Any amendment, repeal, or material modification of the Union Customs Code (Regulation (EU) No. 952/2013), the Combined Nomenclature (Commission Implementing Regulation (EU) 2022/1998 or successors), Greek customs law (Law 2960/2001), the Greek Tax Procedure Code (Law 4174/2013), or any related implementing or delegated regulation that materially affects the classification or valuation issues in dispute, the penalty regime applicable to TSL's case, the administrative objection or judicial appeal process, or the standstill arrangement.
10. Related EU Litigation. The filing or resolution of any preliminary reference to the Court of Justice of the European Union ("CJEU") under Article 267 TFEU, or any judgment of the CJEU or the General Court, addressing the classification of automated gantry cranes, STS cranes, ASC systems, or functionally similar automated port handling equipment under Combined Nomenclature headings 8426 or 8428. This includes references originating from the courts of any EU Member State and judgments in infringement proceedings brought by the Commission under Articles 258–260 TFEU relating to customs classification practices.
The foregoing list of reactivation triggers is intended to be comprehensive but is not exhaustive. Any development that, in the professional judgment of any member of the engagement team, materially affects TSL's legal position, financial exposure, or strategic options shall be treated as a potential reactivation trigger and reported to James Prentice for assessment.
VI. Filing and Records
All matter files are maintained in the Calderwood & Harkness LLP document management system under Matter No. C&H-2022-ITS-04781. The matter is organized into the following sub-matter codes, corresponding to the principal work streams:
• 04781-01 — Classification (CN 8426 vs. CN 8428)
• 04781-02 — Customs Valuation (technology license fees, Nereus procurement fees, commissioning services)
• 04781-03 — BTI Application and DG TAXUD Consultation
• 04781-04 — Insurance Claim (Oceanos Underwriters SA)
• 04781-05 — Lender Notification and Covenant Monitoring (Compass Maritime Bank SA)
• 04781-06 — Peloros Customs Agency Indemnification
• 04781-07 — Administrative Objections (DED proceedings)
• 04781-08 — DG TAXUD Monitoring and Regulatory Developments
• 04781-09 — Client Correspondence
• 04781-10 — Internal Administration (engagement letter, retention letters, billing, dormancy)
Physical files containing originals of executed documents are stored in the Calderwood & Harkness Brussels office secure filing room, Room B-412. The following original documents are maintained in the physical file:
• Engagement letter (executed September 22, 2022)
• Local counsel retention letter — Vournas & Theodorakis (countersigned October 2, 2022)
• Expert retention letter — Argonaut Trade Consulting GmbH (countersigned October 10, 2022)
• Expert retention letter — Kestrel & Palladian LLP (countersigned October 11, 2022)
• Standstill agreement letter (countersigned March 1, 2023)
• Bank guarantee CMB-BG-2023-0291 (original delivered to AADE; certified copy maintained in file)
• BTI Application BTI-GR-2022-003847 (filed copy bearing AADE receipt stamp dated November 15, 2022)
• Administrative objection to AADE/ADAN/2022/0073 — Classification (filed copy)
• Administrative objection to AADE/ADAN/2022/0074 — Valuation (filed copy)
Vournas & Theodorakis maintains parallel files at its Athens offices for all Greek-language originals, filings, and correspondence with AADE, the DED, and the Administrative Court. V&T's files include originals of all documents filed with or received from Greek administrative and judicial authorities, as well as original Greek-language correspondence with Meridian & Drakos.
A comprehensive electronic document index is maintained by Christy Bauer and was last updated as of April 10, 2023. The index shall be updated upon any filing or receipt of new documents during the dormancy period, and shall be comprehensively reviewed and updated upon reactivation.
VII. Billing During Dormancy
Billing on this matter is expected to be minimal during the dormant period. The primary billable activities will consist of the monitoring protocols established in Section III of this memorandum — including DG TAXUD database checks, AADE communication confirmations with local counsel, interest accrual calculations, and quarterly client status updates.
The estimated monthly dormancy costs are approximately $1,500 to $3,000 per month, reflecting one to three hours of associate time per month. The anticipated billing breakdown is as follows:
• Christy Bauer (Senior Associate, current rate: $895/hour) — approximately 1–2 hours per month for DG TAXUD monitoring, quarterly client check-ins, and document index maintenance.
• Garrett Simmons (Associate, current rate: $775/hour) — approximately 0.5–1 hour per month for AADE communication checks, interest accrual calculations, and bank guarantee monitoring.
Partner time is expected to be limited during the dormant period. James Prentice ($1,475/hour) is anticipated to spend time on the matter only for quarterly review of client updates, insurance claim follow-up and coordination with Aether Insurance Brokers Ltd., and assessment of any potential reactivation triggers. Sandra Tung ($1,475/hour) will review billing monthly to confirm that activity levels are consistent with dormancy status and to flag any unexpected increases in billing that may indicate unauthorized reactivation or scope expansion.
Local counsel fees from Vournas & Theodorakis during the dormancy period are estimated at approximately €500 to €1,000 per month, covering standstill compliance monitoring, monthly AADE communication checks, quarterly statute of limitations confirmations, and associated administrative support.
No expert fees are anticipated during the dormancy period. Dr. Lukas Brenner (Argonaut Trade Consulting GmbH) and Spyros Makris (Kestrel & Palladian LLP) have been advised that their work is suspended pending further notice. Expert retention agreements remain in effect, and both experts have confirmed their availability for reactivation. Expert fees would be incurred only if DG TAXUD requests additional technical input in connection with its consultation, which is not expected but cannot be excluded.
Billing shall continue on the standard monthly invoice cycle. If billable activity in a given month is de minimis — for example, limited to a single monitoring check with no substantive findings — invoices may be consolidated and issued on a quarterly basis at Sandra Tung's discretion. All invoices shall be clearly marked to indicate that the matter is in dormant status.
VIII. Key Contact Information During Dormancy
The following table sets forth the key contacts for the matter during the dormant period. All team members should ensure that their contact information remains current in the firm's directory and that any extended absences or departures are communicated in advance to permit reassignment of monitoring responsibilities.
This memorandum constitutes the firm's internal record of the dormancy determination and shall govern the management of Matter No. C&H-2022-ITS-04781 until the matter is reactivated pursuant to Section V. All members of the engagement team are responsible for fulfilling their assigned monitoring obligations as set forth herein.
Please contact either of the undersigned with any questions or concerns.
CALDERWOOD & HARKNESS LLP
By: ________
Christy Bauer Senior Associate, intellectual Property Group Calderwood & Harkness LLP
By: ________
Garrett Simmons Associate, Tax Group Calderwood & Harkness LLP
cc: Matter File — C&H-2022-ITS-04781
Item | Status
Client | Thalassa Shipping & Logistics SA ("TSL") (EORI: GR094827361000; AFM: 094827361)
Matter No. | C&H-2022-ITS-04781
Responsible Partner | James Prentice
Billing Partner | Sandra Tung
Lead Associate | Christy Bauer (Intellectual Property Group)
Working Associate | Garrett Simmons (Tax Group)
Local Counsel | Vournas & Theodorakis (Alexandros Vournas, Managing Partner; Maria-Christina Georgiou, Associate)
Opposing Counsel | Meridian & Drakos Dikigiriko Grafeio (Panagiotis Drakos, Senior Partner; Irini Konstantinou, Associate)
AADE Assessment (mid-case estimate) | Approximately €8,818,620, comprising: duties €1,697,080 + VAT €2,740,416 + penalties €509,124 + interest €3,872,000
AADE Assessment (high-end estimate) | Approximately €14.7 million, including escalated penalties up to €5,091,240 and compounding interest at the statutory rate
Classification Dispute | 20 units (12 STS gantry cranes + 8 ASC systems); TSL classification: CN 8426 41 00 (STS cranes) / CN 8426 19 00 (ASC systems) — 0% duty; AADE classification: CN 8428 90 90 (ASC systems) — 2.2% duty; additional duty assessed: €1,478,400
Valuation Dispute | €9,940,000 adjustment to declared customs value, comprising: €4,900,000 (technology license fees) + €2,940,000 (Nereus procurement fees) + €2,100,000 (commissioning services); additional duty assessed: €218,680
BTI Application | BTI-GR-2022-003847; filed November 15, 2022; referred to DG TAXUD February 7, 2023; pending DG TAXUD consultation
Administrative Objections | Filed November 30, 2022 (ADAN/2022/0073 — Classification; ADAN/2022/0074 — Valuation); DED proceedings held in abeyance pursuant to standstill
Standstill Agreement | In effect since March 1, 2023; terminable on 60 days' written notice or upon resolution of DG TAXUD consultation / issuance of BTI ruling
Bank Guarantee | CMB-BG-2023-0291; €5,000,000; issued March 10, 2023 by Compass Maritime Bank SA
Insurance Claim | Filed October 15, 2022 via Aether Insurance Brokers Ltd.; Oceanos Underwriters SA Financial Lines Policy No. OCU-FIN-2021-GR-0487; customs & excise duty disputes sublimit: €3,000,000; retention: €250,000; reservation of rights issued November 22, 2022; C&H response sent December 12, 2022; definitive coverage determination still pending
Lender Notification | Material litigation disclosure to Compass Maritime Bank SA — sent October 3, 2022
Peloros Indemnification | Demand and preservation letter sent to Peloros Customs Agency S.A. on December 15, 2022; no response received as of the date of this memorandum
Financial Covenant Status | Net Debt / EBITDA at 2.9× (covenant maximum: 3.5×); headroom approximately €27.4 million (based on updated Q4 2022 projections); all modeled scenarios — including full assessment payment — remain within covenant compliance
Date | Action | Responsible
July 1, 2023 | First quarterly client check-in during dormancy (Q3 2023). Status email to Elena Papadimitriou (CFO, TSL) covering: DG TAXUD consultation status, AADE communications, interest accrual update, bank guarantee status, and insurance claim status. Copy James Prentice on all communications. | Christy Bauer
September 1, 2023 | Assess whether to make proactive inquiry to DG TAXUD — either through AADE (via V&T) or directly through the firm's Brussels office — requesting a status update on the BTI consultation referral. Determine whether a direct communication from C&H's Brussels office to the relevant DG TAXUD unit would be appropriate and strategically advisable. | Christy Bauer / James Prentice
October 1, 2023 | Second quarterly client check-in during dormancy (Q4 2023). Status email to Elena Papadimitriou in the same format as the July check-in. | Christy Bauer
January 1, 2024 | One-year dormancy review. Comprehensive assessment of the matter's status and strategic options, including: (a) evaluate whether to take proactive steps to advance the DG TAXUD consultation, such as requesting a meeting with DG TAXUD officials through the Brussels office or submitting additional technical or legal materials in support of TSL's classification position; (b) consider whether to approach AADE for a negotiated settlement on the valuation issues (€218,680 in additional duties) independent of the classification dispute, in order to narrow the overall exposure; (c) review the interest accrual and total exposure trajectory; (d) assess client satisfaction and any changes in TSL's business or financial position. Third quarterly client check-in (Q1 2024). | James Prentice / Christy Bauer / Garrett Simmons
March 1, 2024 | One-year standstill anniversary. Confirm standstill remains in effect. Assess whether AADE or its advisors may be contemplating termination. Consider whether to approach AADE to renegotiate terms of the standstill, including the bank guarantee amount (currently €5,000,000), interest treatment during the standstill period, or other conditions. Coordinate with V&T for an updated assessment of the Greek regulatory and enforcement environment. | Garrett Simmons / V&T
March 31, 2024 | Oceanos Underwriters SA Financial Lines Policy renewal date. Confirm that the policy has been renewed for the period April 1, 2024 through March 31, 2025. Confirm that TSL's claim remains properly notified and that the customs & excise duty disputes sublimit (€3,000,000) and retention (€250,000) remain in force. Follow up on the pending coverage determination — press Oceanos for a definitive position on the reservation of rights issued November 22, 2022. | James Prentice / Fiona Hartwell (Aether Insurance Brokers Ltd.)
April 1, 2024 | Fourth quarterly client check-in during dormancy (Q2 2024). Status email to Elena Papadimitriou. | Christy Bauer
60 days before CMB-BG-2023-0291 expiry | Bank guarantee renewal coordination. Confirm expiry date of guarantee; initiate renewal process with Compass Maritime Bank SA (Andreas Papathanasiou) and TSL (Elena Papadimitriou); confirm renewal in required amount; notify V&T and opposing counsel of renewal. | Garrett Simmons
Role | Name | Contact
C&H Lead Associate | Christy Bauer | christy.bauer@calderwoodharkness.com
C&H Working Associate | Garrett Simmons | garrett.simmons@calderwoodharkness.com
C&H Responsible Partner | James Prentice | james.prentice@calderwoodharkness.com
C&H Billing Partner | Sandra Tung | sandra.tung@calderwoodharkness.com
V&T Managing Partner | Alexandros Vournas (Athens Bar No. 18744) | a.vournas@vournaslaw.gr
V&T Associate | Maria-Christina Georgiou (Athens Bar No. 42917) | mc.georgiou@vournaslaw.gr
Client — Chief Financial Officer | Elena Papadimitriou | Contact details on file (Sub-matter 04781-09)
Client — Chief Executive Officer | Nikolaos Andreadis | Contact details on file (Sub-matter 04781-09)
Insurance Broker | Fiona Hartwell, Aether Insurance Brokers Ltd. | Contact details on file (Sub-matter 04781-04)
Lender Contact | Andreas Papathanasiou, Compass Maritime Bank SA | Contact details on file (Sub-matter 04781-05)

CALDERWOOD & HARKNESS LLP

MEMORANDUM

CALDERWOOD & HARKNESS LLP

Record

Parties

Dates

Amounts