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PRIVILEGED & CONFIDENTIAL

CALDERWOOD & HARKNESS LLP Avenue Louise 480 1050 Brussels, Belgium

Tel: +32 2 894 7100

Fax: +32 2 894 7199

www.calderwoodharkness.com

October 5, 2022

Dr. Lukas Brenner Managing Director Argonaut Trade Consulting GmbH Friedrichstraße 191 10117 Berlin, Germany

Re: Engagement as Independent Customs Classification Expert — Thalassa Shipping & Logistics SA C&H Matter No.: C&H-2022-ITS-04781

Dear Dr. Brenner:

Calderwood & Harkness LLP ("C&H" or the "Firm") represents Thalassa Shipping & Logistics SA ("TSL"), a Greek shipping and logistics company organized as a Société Anonyme (Anonimi Etairia) under the laws of the Hellenic Republic, in connection with a customs classification dispute with the Independent Authority for Public Revenue of the Hellenic Republic (Ανεξάρτητη Αρχή Δημοσίων Εσόδων, "AADE"). The purpose of this letter is to confirm the retention of Argonaut Trade Consulting GmbH ("Argonaut") to provide independent expert analysis and opinion on the proper tariff classification of certain marine cargo-handling equipment under the European Union Combined Nomenclature ("CN"). This letter sets forth the terms and conditions of Argonaut's engagement, including the scope of services, fee arrangements, deliverables timeline, and provisions regarding independence, privilege, and confidentiality.

We are pleased to formalize this engagement and look forward to working with you and your team on this important matter for our client. The following sections describe the factual background, the scope of Argonaut's retention, and the terms governing the engagement.

1. Background

TSL is a Société Anonyme (A.E.) incorporated and registered in the Hellenic Republic, Piraeus Commercial Registry No. 78214/06/B/09/42, with EORI Number GR094827361000, and headquartered at 47 Akti Miaouli, 185 35 Piraeus, Greece. TSL is a leading provider of port logistics, container terminal operations, and maritime cargo-handling services in the eastern Mediterranean region.

Between 2019 and 2022, TSL imported forty-seven (47) units of specialized marine cargo-handling equipment from Hailong Heavy Industries Co., Ltd. ("Hailong"), a Chinese manufacturer of port and heavy engineering equipment located at No. 288 Gangkou Road, Zhenhai District, Ningbo, Zhejiang Province 315200, People's Republic of China (Unified Social Credit Code: 91330211MA2GR8KT5X). The imported equipment comprised the following categories:

(i) Ship-to-Shore (STS) Gantry Cranes: Twelve (12) units, with a total declared CIF value of €38,400,000 (€3,200,000 per unit), imported under Contract HHI-TSL-2019-001 dated January 15, 2019.

(ii) Rubber-Tyred Gantry (RTG) Cranes: Eighteen (18) units (originally ordered under one contract and later supplemented), with a total declared CIF value of €25,200,000, imported under Contract HHI-TSL-2019-002 dated March 22, 2019.

(iii) Automated Stacking Crane (ASC) Systems: Eight (8) units, with a total declared CIF value of €28,800,000 (€3,600,000 per unit), imported under Contract HHI-TSL-2020-003 dated June 10, 2020.

All equipment was imported through the Port of Piraeus and cleared through the Piraeus Regional Customs Office. Customs entries were filed on TSL's behalf by Peloros Customs Agency S.A. (EORI: GR801234567000), a licensed Greek customs brokerage, through its licensed customs broker, Stavros Liapis (License No. GR-CB-1287).

At the time of importation, TSL classified all forty-seven (47) units of equipment — including the STS gantry cranes, RTG cranes, and ASC systems — under Combined Nomenclature code 8426 41 00 ("Self-propelled [machinery], on tyres" — covering cranes and lifting machinery), which carries a 0% Most-Favoured-Nation (MFN) duty rate under the EU Common Customs Tariff.

On April 4, 2022, AADE initiated a post-clearance audit of TSL's customs entries relating to the imported equipment, pursuant to its authority under the Union Customs Code (Regulation (EU) No. 952/2013, the "UCC") and Greek domestic implementing legislation. The audit was completed on August 1, 2022.

On August 12, 2022, AADE issued Additional Duty Assessment Notice AADE/ADAN/2022/0073 (the "Assessment Notice"), contending that twenty (20) of the forty-seven (47) imported units — specifically, the twelve (12) STS gantry cranes and the eight (8) ASC systems, with a combined declared CIF value of €67,200,000 — should be reclassified under CN code 8428 90 90 ("Other lifting, handling, loading, or unloading machinery" — residual subheading), which carries a 2.2% MFN duty rate under the EU Common Customs Tariff.

The eighteen (18) RTG cranes, with a combined declared CIF value of €25,200,000 and imported under Contract HHI-TSL-2019-002, remain undisputed and continue to be classified under CN 8426 41 00 at the 0% MFN duty rate. AADE has not challenged the classification of these units.

As a result of the proposed reclassification, AADE has assessed additional customs duties in the amount of €1,478,400 (calculated as €67,200,000 × 2.2%), exclusive of interest, penalties, and any consequential adjustments to import VAT.

In response to the Assessment Notice, and on the advice of C&H, TSL's local Greek counsel — Vournas & Theodorakis Dikigiriko Grafeio ("V&T") — filed a Binding Tariff Information ("BTI") application with AADE on November 15, 2022, pursuant to Article 33 of the UCC. The BTI application has been assigned reference number BTI-GR-2022-003847. TSL anticipates that AADE may refer the matter to the European Commission's Directorate-General for Taxation and Customs Union ("DG TAXUD") for consultation under Article 34(10) of the UCC, in light of divergent BTI rulings issued by other EU Member States. Specifically:

• The Netherlands customs authority (Douane) issued BTI ruling NL-BTI-2021-01234, classifying similar STS gantry cranes under CN heading 8426 41 00, consistent with TSL's declared classification.

• The German customs authority (Hauptzollamt) issued BTI ruling DE-BTI-2020-05678, classifying similar automated stacking crane equipment under CN heading 8428 90 90, consistent with AADE's position in the Assessment Notice.

The existence of these divergent BTI rulings underscores the classification complexity at the heart of this dispute and heightens the likelihood of DG TAXUD involvement and, potentially, the adoption of a Commission classification regulation under Article 57(4) of the UCC.

AADE is represented in this matter by external legal advisors Meridian & Drakos Dikigiriko Grafeio, with Panagiotis Drakos (Senior Partner, Athens Bar No. 29481) and Irini Konstantinou (Associate) serving as lead counsel. Meridian & Drakos maintains its principal office at 15 Stadiou Street, 105 62 Athens, Greece.

The C&H engagement team for this matter is as follows:

• James Prentice, Partner — Responsible Partner

• Sandra Tung, Partner — Billing Partner

• Christy Bauer, Senior Associate, intellectual Property & Trade Group — Lead Associate

• Garrett Simmons, Associate, Tax & Customs Group — Working Associate

TSL's local Greek counsel is Vournas & Theodorakis Dikigiriko Grafeio ("V&T"), located at 22 Academias Street, 106 71 Athens, Greece. The V&T team includes:

• Alexandros Vournas, Managing Partner (Athens Bar No. 18744)

• Maria-Christina Georgiou, Associate (Athens Bar No. 42917)

2. Scope of Engagement

Argonaut is retained to provide the following services in connection with the customs classification dispute described above:

(a) Classification Analysis

Argonaut will prepare a detailed written analysis of the proper CN classification of TSL's twelve (12) STS gantry cranes and eight (8) ASC systems. The classification analysis will involve a thorough application of:

(i) The General Interpretive Rules ("GIRs") of the Harmonized Commodity Description and Coding System (the "Harmonized System" or "HS"), as adopted by the World Customs Organization ("WCO") and incorporated into the EU Combined Nomenclature;

(ii) The Explanatory Notes to the Harmonized System, as published by the WCO, and the Explanatory Notes to the Combined Nomenclature, as published by the European Commission;

(iii) Relevant classification opinions and decisions of the WCO's Harmonized System Committee, including any opinions addressing the classification of port cranes, gantry cranes, and automated cargo-handling equipment;

(iv) Applicable jurisprudence of the Court of Justice of the European Union ("CJEU") and, where relevant, national courts of EU Member States, regarding the interpretation and application of CN headings 8426 and 8428 to industrial and port machinery.

The classification analysis will specifically assess whether the STS gantry cranes and ASC systems properly fall under CN heading 8426 (which covers cranes and other lifting machinery, including tower cranes, portal or pedestal jib cranes, and other self-propelled machinery, with a 0% MFN duty rate) or whether AADE's proposed reclassification under CN heading 8428 (which covers other lifting, handling, loading, or unloading machinery — specifically the residual subheading 8428 90 90 — at a 2.2% MFN duty rate) is correct.

The analysis will also address the relevance, if any, of the degree of automation of the equipment to heading-level classification. Specifically, the analysis should consider whether the distinction between the semi-automated STS gantry cranes (which require operator input for certain functions) and the fully automated ASC systems (which operate autonomously within a container stacking yard) affects classification at the heading level, or whether both types of equipment share sufficient structural and functional characteristics to warrant classification under the same CN heading.

(b) Expert Report

Argonaut will prepare a formal expert report setting forth its independent professional opinion on the correct CN classification of both the STS gantry cranes and the ASC systems. The expert report shall be suitable for submission to AADE in connection with the BTI application (BTI-GR-2022-003847) and the administrative challenge to the Assessment Notice (AADE/ADAN/2022/0073), and, if necessary, for submission to the European Commission's DG TAXUD or the Administrative Court of First Instance of Piraeus (Διοικητικό Πρωτοδικείο Πειραιώς) in the event that the dispute proceeds to judicial review.

The expert report shall, at a minimum:

(i) Describe and analyze the structural and functional characteristics of the STS gantry cranes and ASC systems, including the gantry structure, trolley system, wire rope hoist mechanism, headblock assembly, spreader, and associated control systems;

(ii) Explain why these structural and functional characteristics support classification under CN heading 8426, with reference to the technical operation of the equipment and the scope of the relevant CN headings as defined by the GIRs, Explanatory Notes, and HS Committee opinions;

(iii) Address and rebut AADE's classification arguments, including its reliance on CN heading 8428 and the residual subheading 8428 90 90;

(iv) Analyze the relevance (or lack thereof) of automation features to heading-level classification;

(v) Set forth Dr. Brenner's qualifications, experience, and basis for his opinion.

Argonaut will provide technical input for the Binding Tariff Information application BTI-GR-2022-003847 filed with AADE. This support will include the preparation of equipment functional descriptions, analysis of technical specifications, and identification and articulation of classification-relevant characteristics for inclusion in the BTI application and its Technical Annex. Argonaut will review and comment on the Technical Annex to the BTI application as drafted by C&H and V&T, and will ensure that the technical descriptions are accurate, complete, and consistent with the classification position advanced in the expert report.

(d) Comparative BTI Analysis Support

Argonaut will analyze the reasoning and conclusions of the two divergent BTI rulings identified above:

(i) The Dutch BTI ruling NL-BTI-2021-01234, which classified STS gantry cranes similar to TSL's equipment under CN heading 8426 41 00, supporting TSL's declared classification;

(ii) The German BTI ruling DE-BTI-2020-05678, which classified automated stacking crane systems similar to TSL's ASC units under CN heading 8428 90 90, supporting AADE's proposed reclassification.

Argonaut's analysis will identify the analytical strengths and weaknesses of each ruling, assess the consistency of each ruling with the GIRs, Explanatory Notes, and HS Committee opinions, and provide input for any supplemental submission that C&H and V&T may prepare for DG TAXUD following a referral under Article 34(10) of the UCC.

(e) Consultation. Argonaut will make itself available for consultations with the C&H engagement team — specifically Christy Bauer (Senior Associate, lead on day-to-day coordination and classification analysis) and Garrett Simmons (Associate, responsible for valuation-related classification issues and duty calculations) — and with TSL's technical personnel, including Dimitrios Sarantopoulos, Vice President of Procurement & Supply Chain at TSL, regarding equipment functionality, design, and operational characteristics relevant to classification.

Argonaut will also be available to review and comment on equipment technical data sheets, product brochures, engineering drawings, and other technical documentation provided by Hailong Heavy Industries Co., Ltd. (primary contact: Wei Junhao, Export Sales Director). Such review will be conducted for the purpose of ensuring that Argonaut's classification analysis and expert report are grounded in a thorough understanding of the equipment's technical characteristics.

(f) Testimony. If required by the progress of the dispute, Argonaut (through Dr. Brenner) will provide expert testimony before the Administrative Court of First Instance of Piraeus or any other Greek administrative tribunal with jurisdiction over this matter. In advance of any hearing at which Dr. Brenner may be called to testify, C&H will conduct testimony preparation sessions with Dr. Brenner to ensure that his testimony is clear, well-organized, and consistent with the expert report and Argonaut's classification analysis.

3. Expert Qualifications

Dr. Lukas Brenner will serve as the primary expert and sole author of the expert report prepared under this engagement. Dr. Brenner's qualifications are summarized as follows:

• World Customs Organization: Former member of the WCO's Harmonized System Committee (2008–2016), where he participated in classification discussions, reviewed classification opinions, and contributed to the development of guidance on the classification of industrial machinery and capital equipment.

• Academic Credentials: Doctorate in Mechanical Engineering (Dr.-Ing.) from the Technische Universität München, with a dissertation on the structural dynamics of overhead crane systems.

• Professional Experience: Over twenty (20) years of experience in customs classification of industrial machinery, port equipment, and heavy engineering products, advising manufacturers, importers, logistics companies, and government agencies across the European Union and internationally.

• Current Position: Managing Director of Argonaut Trade Consulting GmbH, a Berlin-based customs classification consulting firm specializing in the tariff classification of complex machinery, equipment, and technology products under the Harmonized System and the EU Combined Nomenclature.

Dr. Brenner's full curriculum vitae, including a comprehensive list of publications, prior expert engagements, and professional affiliations, will be provided as an appendix to the expert report.

Dr. Brenner may be supported by senior consultants and research staff at Argonaut as needed in connection with this engagement. All such supporting personnel shall be subject to the privilege and confidentiality provisions set forth in Section 7 below, and Dr. Brenner shall remain personally responsible for the content and conclusions of the expert report.

4. Deliverables and Timeline

The following deliverables are anticipated under this engagement, subject to the timelines set forth below:

The above timelines may be adjusted by mutual written agreement between Argonaut and C&H, taking into account the pace of the administrative proceedings, the availability of technical documentation from Hailong, and any requests from AADE or DG TAXUD.

Any additional deliverables beyond those identified above — including, without limitation, supplemental analyses prepared in response to DG TAXUD inquiries, rebuttal memoranda addressing AADE's classification arguments, or revised expert reports incorporating new factual developments — will be agreed upon separately between Argonaut and C&H, with corresponding adjustments to the timeline and fee estimate as appropriate.

5. Fee Arrangements

Argonaut's fees for the services described in this engagement letter will be calculated on the basis of the following hourly and per-diem rates:

Argonaut will invoice TSL directly on a monthly basis for services rendered during the preceding calendar month. Copies of all invoices shall be provided contemporaneously to C&H, directed to the attention of Christy Bauer (christy.bauer@calderwoodharkness.com) and Garrett Simmons (garrett.simmons@calderwoodharkness.com). Invoices shall include a reasonably detailed description of the services performed, the number of hours worked by each timekeeper, and the applicable rate.

Reasonable out-of-pocket expenses incurred by Argonaut in connection with this engagement — including, without limitation, travel to Athens and Piraeus for consultations with C&H, V&T, or TSL technical personnel, or for site visits to the Port of Piraeus; travel to Brussels for any DG TAXUD proceedings or meetings; and document production and courier costs — will be billed at cost, without markup. Argonaut will seek C&H's prior approval for any single expense or category of expenses expected to exceed €2,000.

Total fees for the initial phase of this engagement — through delivery of the final expert report (as described in Section 4 above), excluding testimony, testimony preparation, and any supplemental work arising from DG TAXUD referral proceedings — are estimated at €45,000 to €65,000. This estimate is provided for budgeting purposes only and does not constitute a fee cap or maximum. Argonaut will notify C&H promptly if, in the course of the engagement, it appears that the fee estimate will be materially exceeded, so that C&H and TSL may evaluate the scope and budget for the engagement accordingly.

Payment terms: All invoices are due and payable within thirty (30) days of the invoice date. Late payments shall bear interest at the rate of 5% per annum above the base rate of the European Central Bank, calculated from the date payment was due until the date of actual receipt.

6. Independence

Argonaut confirms that it is independent of each of the following parties and entities, and that neither Dr. Brenner nor any Argonaut personnel has a current or prior professional, financial, or personal relationship with any of the following that could impair, or could reasonably appear to impair, Argonaut's independence or objectivity in connection with this engagement:

(a) Thalassa Shipping & Logistics SA and all affiliated entities, including Andreadis Family Holdings LLC and Nereus Maritime Advisory Limited;

(b) Hailong Heavy Industries Co., Ltd.;

(d) Meridian & Drakos Dikigiriko Grafeio, AADE's external legal advisors in this matter, including Panagiotis Drakos and Irini Konstantinou;

(e) Peloros Customs Agency S.A. and its licensed customs broker, Stavros Liapis;

(f) All other parties to this matter known to Argonaut as of the date of this letter.

Argonaut's opinion will be based solely on its independent professional judgment, applying its expertise in customs classification, the Harmonized System, and the EU Combined Nomenclature. Argonaut's conclusions will not be influenced by the interests or preferences of TSL, C&H, or any other party. Argonaut understands that its value as an expert depends on the independence, rigor, and objectivity of its analysis.

Argonaut will promptly notify C&H in writing if any circumstance arises during the course of the engagement that could affect, or could reasonably be perceived to affect, Argonaut's independence or objectivity, including any new professional engagement, financial interest, or personal relationship involving any of the parties listed above.

7. Privilege and Confidentiality

Argonaut is engaged as a consulting and testifying expert at the direction of counsel (Calderwood & Harkness LLP) in connection with pending and anticipated administrative and judicial proceedings arising from AADE's Additional Duty Assessment Notice AADE/ADAN/2022/0073 and the BTI application BTI-GR-2022-003847.

All communications between Argonaut, C&H, V&T (Vournas & Theodorakis Dikigiriko Grafeio, local Greek counsel for TSL), and TSL in connection with this engagement are intended to be privileged and confidential to the fullest extent permitted by applicable law, including under the attorney-client privilege, the attorney work-product doctrine, and the common-interest privilege (as among co-counsel and client). Argonaut acknowledges that its role as an expert retained by counsel carries with it obligations to protect the confidentiality of privileged communications and work product.

Draft work product, internal analyses, preliminary opinions, notes, memoranda, and other materials shared between Argonaut and C&H in the course of this engagement shall be treated as attorney work product and shall not be disclosed to any third party without C&H's prior written consent. Argonaut understands that the decision to designate any portion of Argonaut's work product as a final report or filing — and thereby to waive work-product protection with respect to that material — rests exclusively with C&H, in consultation with TSL.

Final expert reports intended for submission to AADE, DG TAXUD, or any court or administrative tribunal will be disclosed only with C&H's express written authorization and in coordination with C&H's overall litigation and administrative strategy. Argonaut will not independently submit or disclose any report, analysis, or communication to any governmental authority, opposing party, or other third party.

Argonaut shall not disclose any information received in connection with this engagement — including but not limited to equipment specifications, technical data sheets, engineering drawings, product brochures, commercial terms, contract provisions, legal strategy, litigation analysis, or client communications — to any third party without C&H's prior written consent. This obligation extends to all Argonaut personnel, including senior consultants and research staff who may assist Dr. Brenner in connection with this engagement.

Argonaut's confidentiality obligations under this Section 7 survive the termination of this engagement, regardless of the reason for termination, and shall remain in effect indefinitely.

8. Document Handling and Data Protection

Argonaut will maintain all documents and data received in connection with this engagement — whether in physical or electronic form — in a secure manner, consistent with applicable data protection laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR"). Argonaut will implement appropriate technical and organizational measures to protect the confidentiality, integrity, and availability of such documents and data, and will restrict access to such materials to those Argonaut personnel who have a need to know in connection with this engagement and who are bound by confidentiality obligations consistent with this letter.

Upon termination of the engagement or at C&H's written request, Argonaut will return or securely destroy all confidential documents and data received in connection with this engagement, and will certify such return or destruction in writing to C&H. Argonaut's obligation to return or destroy confidential documents and data is subject to any legal or regulatory retention requirements applicable to Argonaut under German law or other applicable law, provided that Argonaut will continue to maintain the confidentiality of any retained materials in accordance with this letter.

9. Termination

Either party may terminate this engagement upon fifteen (15) days' prior written notice to the other party. Such notice shall be delivered to the contact addresses specified in Section 11 below (or to such other address as a party may designate in writing).

In the event of termination, Argonaut will be compensated for all work performed and all expenses incurred through the effective date of termination, in accordance with the fee arrangements set forth in Section 5. Argonaut will submit a final invoice within thirty (30) days following the effective date of termination.

Upon termination, Argonaut will promptly deliver to C&H all work product completed through the date of termination, including all drafts, memoranda, analyses, reports, notes, and other materials prepared in connection with this engagement, regardless of whether such work product is in final or preliminary form.

The confidentiality and privilege obligations set forth in Sections 7 and 8 above shall survive the termination of this engagement and shall remain in full force and effect.

10. Governing Law

This engagement letter shall be governed by and construed in accordance with the laws of the Federal Republic of Germany, without regard to conflicts-of-law principles that would result in the application of the law of any other jurisdiction.

Any disputes arising out of or relating to this engagement letter, or the breach, termination, or validity thereof, shall be resolved exclusively by the competent courts of Berlin, Germany. Each party hereby consents to the personal jurisdiction and venue of such courts.

11. Points of Contact

The primary points of contact for this engagement are as follows:

Calderwood & Harkness LLP:

Christy Bauer, Senior Associate Intellectual Property & Trade Group

Email: christy.bauer@calderwoodharkness.com

Tel: +32 2 894 7142 (Day-to-day coordination, classification analysis, BTI application)

Garrett Simmons, Associate Tax & Customs Group

Email: garrett.simmons@calderwoodharkness.com

Tel: +32 2 894 7158 (Valuation-related classification issues, duty calculations)

James Prentice, Partner

Email: james.prentice@calderwoodharkness.com

Tel: +32 2 894 7110 (Responsible Partner; to be copied on all substantive communications)

Argonaut Trade Consulting GmbH:

Dr. Lukas Brenner, Managing Director

Email: l.brenner@argonaut-trade.de

Tel: +49 30 2093 4400

All substantive communications, draft work product, and expert materials should be addressed to Christy Bauer, with copies to Garrett Simmons and James Prentice, unless otherwise directed by C&H. Communications may be conducted by email, provided that confidential attachments are transmitted via encrypted file-sharing or secure courier, as appropriate.

12. Acceptance

If the foregoing terms and conditions accurately reflect our mutual understanding regarding Argonaut's engagement, we respectfully request that Dr. Brenner countersign and return a copy of this letter to Christy Bauer at the email address set forth above, thereby confirming Argonaut's acceptance of this retention. A countersigned copy returned by email in PDF format will be accepted as an original for purposes of this engagement.

We look forward to working with you and the Argonaut team on this important matter for our client, and we are confident that your expertise will be invaluable to the resolution of this classification dispute.

Sincerely,

CALDERWOOD & HARKNESS LLP

By: ________

Name: Christy Bauer

Title: Senior Associate

(On behalf of and with the authorization of James Prentice, Partner)

ACCEPTED AND AGREED:

ARGONAUT TRADE CONSULTING GmbH

By: ________

Name: Dr. Lukas Brenner

Title: Managing Director

Date: October 10, 2022

Deliverable	Description	Target Date
Technical Input for BTI Application	Equipment functional descriptions and technical specifications for inclusion in the Technical Annex to BTI application BTI-GR-2022-003847	November 1, 2022
Preliminary Classification Analysis	Draft memorandum analyzing the CN classification of the STS gantry cranes and ASC systems under the GIRs, Explanatory Notes to the HS and CN, and relevant HS Committee classification opinions	November 15, 2022
Draft Expert Report	Formal expert report suitable for submission to AADE, DG TAXUD, and/or the Administrative Court of First Instance of Piraeus, setting forth Argonaut's independent professional opinion on the correct CN classification	January 15, 2023
Final Expert Report	Finalized expert report incorporating review comments from C&H and prepared for filing	February 15, 2023
Service	Rate
Dr. Lukas Brenner — Expert analysis, report preparation, and consultation	€450 per hour
Senior Consultant support (at Argonaut)	€320 per hour
Research and administrative support (at Argonaut)	€180 per hour
Expert testimony (including preparation time) — Half-day	€5,000 per half-day
Expert testimony (including preparation time) — Full day	€9,000 per full day

PRIVILEGED & CONFIDENTIAL
CALDERWOOD & HARKNESS LLP Avenue Louise 480 1050 Brussels, Belgium
Tel: +32 2 894 7100
Fax: +32 2 894 7199
www.calderwoodharkness.com
October 5, 2022
Dr. Lukas Brenner Managing Director Argonaut Trade Consulting GmbH Friedrichstraße 191 10117 Berlin, Germany
Re: Engagement as Independent Customs Classification Expert — Thalassa Shipping & Logistics SA C&H Matter No.: C&H-2022-ITS-04781
Dear Dr. Brenner:
Calderwood & Harkness LLP ("C&H" or the "Firm") represents Thalassa Shipping & Logistics SA ("TSL"), a Greek shipping and logistics company organized as a Société Anonyme (Anonimi Etairia) under the laws of the Hellenic Republic, in connection with a customs classification dispute with the Independent Authority for Public Revenue of the Hellenic Republic (Ανεξάρτητη Αρχή Δημοσίων Εσόδων, "AADE"). The purpose of this letter is to confirm the retention of Argonaut Trade Consulting GmbH ("Argonaut") to provide independent expert analysis and opinion on the proper tariff classification of certain marine cargo-handling equipment under the European Union Combined Nomenclature ("CN"). This letter sets forth the terms and conditions of Argonaut's engagement, including the scope of services, fee arrangements, deliverables timeline, and provisions regarding independence, privilege, and confidentiality.
We are pleased to formalize this engagement and look forward to working with you and your team on this important matter for our client. The following sections describe the factual background, the scope of Argonaut's retention, and the terms governing the engagement.
1. Background
TSL is a Société Anonyme (A.E.) incorporated and registered in the Hellenic Republic, Piraeus Commercial Registry No. 78214/06/B/09/42, with EORI Number GR094827361000, and headquartered at 47 Akti Miaouli, 185 35 Piraeus, Greece. TSL is a leading provider of port logistics, container terminal operations, and maritime cargo-handling services in the eastern Mediterranean region.
Between 2019 and 2022, TSL imported forty-seven (47) units of specialized marine cargo-handling equipment from Hailong Heavy Industries Co., Ltd. ("Hailong"), a Chinese manufacturer of port and heavy engineering equipment located at No. 288 Gangkou Road, Zhenhai District, Ningbo, Zhejiang Province 315200, People's Republic of China (Unified Social Credit Code: 91330211MA2GR8KT5X). The imported equipment comprised the following categories:
(i) Ship-to-Shore (STS) Gantry Cranes: Twelve (12) units, with a total declared CIF value of €38,400,000 (€3,200,000 per unit), imported under Contract HHI-TSL-2019-001 dated January 15, 2019.
(ii) Rubber-Tyred Gantry (RTG) Cranes: Eighteen (18) units (originally ordered under one contract and later supplemented), with a total declared CIF value of €25,200,000, imported under Contract HHI-TSL-2019-002 dated March 22, 2019.
(iii) Automated Stacking Crane (ASC) Systems: Eight (8) units, with a total declared CIF value of €28,800,000 (€3,600,000 per unit), imported under Contract HHI-TSL-2020-003 dated June 10, 2020.
All equipment was imported through the Port of Piraeus and cleared through the Piraeus Regional Customs Office. Customs entries were filed on TSL's behalf by Peloros Customs Agency S.A. (EORI: GR801234567000), a licensed Greek customs brokerage, through its licensed customs broker, Stavros Liapis (License No. GR-CB-1287).
At the time of importation, TSL classified all forty-seven (47) units of equipment — including the STS gantry cranes, RTG cranes, and ASC systems — under Combined Nomenclature code 8426 41 00 ("Self-propelled [machinery], on tyres" — covering cranes and lifting machinery), which carries a 0% Most-Favoured-Nation (MFN) duty rate under the EU Common Customs Tariff.
On April 4, 2022, AADE initiated a post-clearance audit of TSL's customs entries relating to the imported equipment, pursuant to its authority under the Union Customs Code (Regulation (EU) No. 952/2013, the "UCC") and Greek domestic implementing legislation. The audit was completed on August 1, 2022.
On August 12, 2022, AADE issued Additional Duty Assessment Notice AADE/ADAN/2022/0073 (the "Assessment Notice"), contending that twenty (20) of the forty-seven (47) imported units — specifically, the twelve (12) STS gantry cranes and the eight (8) ASC systems, with a combined declared CIF value of €67,200,000 — should be reclassified under CN code 8428 90 90 ("Other lifting, handling, loading, or unloading machinery" — residual subheading), which carries a 2.2% MFN duty rate under the EU Common Customs Tariff.
The eighteen (18) RTG cranes, with a combined declared CIF value of €25,200,000 and imported under Contract HHI-TSL-2019-002, remain undisputed and continue to be classified under CN 8426 41 00 at the 0% MFN duty rate. AADE has not challenged the classification of these units.
As a result of the proposed reclassification, AADE has assessed additional customs duties in the amount of €1,478,400 (calculated as €67,200,000 × 2.2%), exclusive of interest, penalties, and any consequential adjustments to import VAT.
In response to the Assessment Notice, and on the advice of C&H, TSL's local Greek counsel — Vournas & Theodorakis Dikigiriko Grafeio ("V&T") — filed a Binding Tariff Information ("BTI") application with AADE on November 15, 2022, pursuant to Article 33 of the UCC. The BTI application has been assigned reference number BTI-GR-2022-003847. TSL anticipates that AADE may refer the matter to the European Commission's Directorate-General for Taxation and Customs Union ("DG TAXUD") for consultation under Article 34(10) of the UCC, in light of divergent BTI rulings issued by other EU Member States. Specifically:
•  The Netherlands customs authority (Douane) issued BTI ruling NL-BTI-2021-01234, classifying similar STS gantry cranes under CN heading 8426 41 00, consistent with TSL's declared classification.
•  The German customs authority (Hauptzollamt) issued BTI ruling DE-BTI-2020-05678, classifying similar automated stacking crane equipment under CN heading 8428 90 90, consistent with AADE's position in the Assessment Notice.
The existence of these divergent BTI rulings underscores the classification complexity at the heart of this dispute and heightens the likelihood of DG TAXUD involvement and, potentially, the adoption of a Commission classification regulation under Article 57(4) of the UCC.
AADE is represented in this matter by external legal advisors Meridian & Drakos Dikigiriko Grafeio, with Panagiotis Drakos (Senior Partner, Athens Bar No. 29481) and Irini Konstantinou (Associate) serving as lead counsel. Meridian & Drakos maintains its principal office at 15 Stadiou Street, 105 62 Athens, Greece.
The C&H engagement team for this matter is as follows:
•  James Prentice, Partner — Responsible Partner
•  Sandra Tung, Partner — Billing Partner
•  Christy Bauer, Senior Associate, intellectual Property & Trade Group — Lead Associate
•  Garrett Simmons, Associate, Tax & Customs Group — Working Associate
TSL's local Greek counsel is Vournas & Theodorakis Dikigiriko Grafeio ("V&T"), located at 22 Academias Street, 106 71 Athens, Greece. The V&T team includes:
•  Alexandros Vournas, Managing Partner (Athens Bar No. 18744)
•  Maria-Christina Georgiou, Associate (Athens Bar No. 42917)
2. Scope of Engagement
Argonaut is retained to provide the following services in connection with the customs classification dispute described above:
(a) Classification Analysis
Argonaut will prepare a detailed written analysis of the proper CN classification of TSL's twelve (12) STS gantry cranes and eight (8) ASC systems. The classification analysis will involve a thorough application of:
(i) The General Interpretive Rules ("GIRs") of the Harmonized Commodity Description and Coding System (the "Harmonized System" or "HS"), as adopted by the World Customs Organization ("WCO") and incorporated into the EU Combined Nomenclature;
(ii) The Explanatory Notes to the Harmonized System, as published by the WCO, and the Explanatory Notes to the Combined Nomenclature, as published by the European Commission;
(iii) Relevant classification opinions and decisions of the WCO's Harmonized System Committee, including any opinions addressing the classification of port cranes, gantry cranes, and automated cargo-handling equipment;
(iv) Applicable jurisprudence of the Court of Justice of the European Union ("CJEU") and, where relevant, national courts of EU Member States, regarding the interpretation and application of CN headings 8426 and 8428 to industrial and port machinery.
The classification analysis will specifically assess whether the STS gantry cranes and ASC systems properly fall under CN heading 8426 (which covers cranes and other lifting machinery, including tower cranes, portal or pedestal jib cranes, and other self-propelled machinery, with a 0% MFN duty rate) or whether AADE's proposed reclassification under CN heading 8428 (which covers other lifting, handling, loading, or unloading machinery — specifically the residual subheading 8428 90 90 — at a 2.2% MFN duty rate) is correct.
The analysis will also address the relevance, if any, of the degree of automation of the equipment to heading-level classification. Specifically, the analysis should consider whether the distinction between the semi-automated STS gantry cranes (which require operator input for certain functions) and the fully automated ASC systems (which operate autonomously within a container stacking yard) affects classification at the heading level, or whether both types of equipment share sufficient structural and functional characteristics to warrant classification under the same CN heading.
(b) Expert Report
Argonaut will prepare a formal expert report setting forth its independent professional opinion on the correct CN classification of both the STS gantry cranes and the ASC systems. The expert report shall be suitable for submission to AADE in connection with the BTI application (BTI-GR-2022-003847) and the administrative challenge to the Assessment Notice (AADE/ADAN/2022/0073), and, if necessary, for submission to the European Commission's DG TAXUD or the Administrative Court of First Instance of Piraeus (Διοικητικό Πρωτοδικείο Πειραιώς) in the event that the dispute proceeds to judicial review.
The expert report shall, at a minimum:
(i) Describe and analyze the structural and functional characteristics of the STS gantry cranes and ASC systems, including the gantry structure, trolley system, wire rope hoist mechanism, headblock assembly, spreader, and associated control systems;
(ii) Explain why these structural and functional characteristics support classification under CN heading 8426, with reference to the technical operation of the equipment and the scope of the relevant CN headings as defined by the GIRs, Explanatory Notes, and HS Committee opinions;
(iii) Address and rebut AADE's classification arguments, including its reliance on CN heading 8428 and the residual subheading 8428 90 90;
(iv) Analyze the relevance (or lack thereof) of automation features to heading-level classification;
(v) Set forth Dr. Brenner's qualifications, experience, and basis for his opinion.
(c) BTI Application Support
Argonaut will provide technical input for the Binding Tariff Information application BTI-GR-2022-003847 filed with AADE. This support will include the preparation of equipment functional descriptions, analysis of technical specifications, and identification and articulation of classification-relevant characteristics for inclusion in the BTI application and its Technical Annex. Argonaut will review and comment on the Technical Annex to the BTI application as drafted by C&H and V&T, and will ensure that the technical descriptions are accurate, complete, and consistent with the classification position advanced in the expert report.
(d) Comparative BTI Analysis Support
Argonaut will analyze the reasoning and conclusions of the two divergent BTI rulings identified above:
(i) The Dutch BTI ruling NL-BTI-2021-01234, which classified STS gantry cranes similar to TSL's equipment under CN heading 8426 41 00, supporting TSL's declared classification;
(ii) The German BTI ruling DE-BTI-2020-05678, which classified automated stacking crane systems similar to TSL's ASC units under CN heading 8428 90 90, supporting AADE's proposed reclassification.
Argonaut's analysis will identify the analytical strengths and weaknesses of each ruling, assess the consistency of each ruling with the GIRs, Explanatory Notes, and HS Committee opinions, and provide input for any supplemental submission that C&H and V&T may prepare for DG TAXUD following a referral under Article 34(10) of the UCC.
(e) Consultation.  Argonaut will make itself available for consultations with the C&H engagement team — specifically Christy Bauer (Senior Associate, lead on day-to-day coordination and classification analysis) and Garrett Simmons (Associate, responsible for valuation-related classification issues and duty calculations) — and with TSL's technical personnel, including Dimitrios Sarantopoulos, Vice President of Procurement & Supply Chain at TSL, regarding equipment functionality, design, and operational characteristics relevant to classification.
Argonaut will also be available to review and comment on equipment technical data sheets, product brochures, engineering drawings, and other technical documentation provided by Hailong Heavy Industries Co., Ltd. (primary contact: Wei Junhao, Export Sales Director). Such review will be conducted for the purpose of ensuring that Argonaut's classification analysis and expert report are grounded in a thorough understanding of the equipment's technical characteristics.
(f) Testimony.  If required by the progress of the dispute, Argonaut (through Dr. Brenner) will provide expert testimony before the Administrative Court of First Instance of Piraeus or any other Greek administrative tribunal with jurisdiction over this matter. In advance of any hearing at which Dr. Brenner may be called to testify, C&H will conduct testimony preparation sessions with Dr. Brenner to ensure that his testimony is clear, well-organized, and consistent with the expert report and Argonaut's classification analysis.
3. Expert Qualifications
Dr. Lukas Brenner will serve as the primary expert and sole author of the expert report prepared under this engagement. Dr. Brenner's qualifications are summarized as follows:
•  World Customs Organization: Former member of the WCO's Harmonized System Committee (2008–2016), where he participated in classification discussions, reviewed classification opinions, and contributed to the development of guidance on the classification of industrial machinery and capital equipment.
•  Academic Credentials: Doctorate in Mechanical Engineering (Dr.-Ing.) from the Technische Universität München, with a dissertation on the structural dynamics of overhead crane systems.
•  Professional Experience: Over twenty (20) years of experience in customs classification of industrial machinery, port equipment, and heavy engineering products, advising manufacturers, importers, logistics companies, and government agencies across the European Union and internationally.
•  Current Position: Managing Director of Argonaut Trade Consulting GmbH, a Berlin-based customs classification consulting firm specializing in the tariff classification of complex machinery, equipment, and technology products under the Harmonized System and the EU Combined Nomenclature.
Dr. Brenner's full curriculum vitae, including a comprehensive list of publications, prior expert engagements, and professional affiliations, will be provided as an appendix to the expert report.
Dr. Brenner may be supported by senior consultants and research staff at Argonaut as needed in connection with this engagement. All such supporting personnel shall be subject to the privilege and confidentiality provisions set forth in Section 7 below, and Dr. Brenner shall remain personally responsible for the content and conclusions of the expert report.
4. Deliverables and Timeline
The following deliverables are anticipated under this engagement, subject to the timelines set forth below:
The above timelines may be adjusted by mutual written agreement between Argonaut and C&H, taking into account the pace of the administrative proceedings, the availability of technical documentation from Hailong, and any requests from AADE or DG TAXUD.
Any additional deliverables beyond those identified above — including, without limitation, supplemental analyses prepared in response to DG TAXUD inquiries, rebuttal memoranda addressing AADE's classification arguments, or revised expert reports incorporating new factual developments — will be agreed upon separately between Argonaut and C&H, with corresponding adjustments to the timeline and fee estimate as appropriate.
5. Fee Arrangements
Argonaut's fees for the services described in this engagement letter will be calculated on the basis of the following hourly and per-diem rates:
Argonaut will invoice TSL directly on a monthly basis for services rendered during the preceding calendar month. Copies of all invoices shall be provided contemporaneously to C&H, directed to the attention of Christy Bauer (christy.bauer@calderwoodharkness.com) and Garrett Simmons (garrett.simmons@calderwoodharkness.com). Invoices shall include a reasonably detailed description of the services performed, the number of hours worked by each timekeeper, and the applicable rate.
Reasonable out-of-pocket expenses incurred by Argonaut in connection with this engagement — including, without limitation, travel to Athens and Piraeus for consultations with C&H, V&T, or TSL technical personnel, or for site visits to the Port of Piraeus; travel to Brussels for any DG TAXUD proceedings or meetings; and document production and courier costs — will be billed at cost, without markup. Argonaut will seek C&H's prior approval for any single expense or category of expenses expected to exceed €2,000.
Total fees for the initial phase of this engagement — through delivery of the final expert report (as described in Section 4 above), excluding testimony, testimony preparation, and any supplemental work arising from DG TAXUD referral proceedings — are estimated at €45,000 to €65,000. This estimate is provided for budgeting purposes only and does not constitute a fee cap or maximum. Argonaut will notify C&H promptly if, in the course of the engagement, it appears that the fee estimate will be materially exceeded, so that C&H and TSL may evaluate the scope and budget for the engagement accordingly.
Payment terms: All invoices are due and payable within thirty (30) days of the invoice date. Late payments shall bear interest at the rate of 5% per annum above the base rate of the European Central Bank, calculated from the date payment was due until the date of actual receipt.
6. Independence
Argonaut confirms that it is independent of each of the following parties and entities, and that neither Dr. Brenner nor any Argonaut personnel has a current or prior professional, financial, or personal relationship with any of the following that could impair, or could reasonably appear to impair, Argonaut's independence or objectivity in connection with this engagement:
(a) Thalassa Shipping & Logistics SA and all affiliated entities, including Andreadis Family Holdings LLC and Nereus Maritime Advisory Limited;
(b) Hailong Heavy Industries Co., Ltd.;
(c) AADE (the Independent Authority for Public Revenue of the Hellenic Republic);
(d) Meridian & Drakos Dikigiriko Grafeio, AADE's external legal advisors in this matter, including Panagiotis Drakos and Irini Konstantinou;
(e) Peloros Customs Agency S.A. and its licensed customs broker, Stavros Liapis;
(f) All other parties to this matter known to Argonaut as of the date of this letter.
Argonaut's opinion will be based solely on its independent professional judgment, applying its expertise in customs classification, the Harmonized System, and the EU Combined Nomenclature. Argonaut's conclusions will not be influenced by the interests or preferences of TSL, C&H, or any other party. Argonaut understands that its value as an expert depends on the independence, rigor, and objectivity of its analysis.
Argonaut will promptly notify C&H in writing if any circumstance arises during the course of the engagement that could affect, or could reasonably be perceived to affect, Argonaut's independence or objectivity, including any new professional engagement, financial interest, or personal relationship involving any of the parties listed above.
7. Privilege and Confidentiality
Argonaut is engaged as a consulting and testifying expert at the direction of counsel (Calderwood & Harkness LLP) in connection with pending and anticipated administrative and judicial proceedings arising from AADE's Additional Duty Assessment Notice AADE/ADAN/2022/0073 and the BTI application BTI-GR-2022-003847.
All communications between Argonaut, C&H, V&T (Vournas & Theodorakis Dikigiriko Grafeio, local Greek counsel for TSL), and TSL in connection with this engagement are intended to be privileged and confidential to the fullest extent permitted by applicable law, including under the attorney-client privilege, the attorney work-product doctrine, and the common-interest privilege (as among co-counsel and client). Argonaut acknowledges that its role as an expert retained by counsel carries with it obligations to protect the confidentiality of privileged communications and work product.
Draft work product, internal analyses, preliminary opinions, notes, memoranda, and other materials shared between Argonaut and C&H in the course of this engagement shall be treated as attorney work product and shall not be disclosed to any third party without C&H's prior written consent. Argonaut understands that the decision to designate any portion of Argonaut's work product as a final report or filing — and thereby to waive work-product protection with respect to that material — rests exclusively with C&H, in consultation with TSL.
Final expert reports intended for submission to AADE, DG TAXUD, or any court or administrative tribunal will be disclosed only with C&H's express written authorization and in coordination with C&H's overall litigation and administrative strategy. Argonaut will not independently submit or disclose any report, analysis, or communication to any governmental authority, opposing party, or other third party.
Argonaut shall not disclose any information received in connection with this engagement — including but not limited to equipment specifications, technical data sheets, engineering drawings, product brochures, commercial terms, contract provisions, legal strategy, litigation analysis, or client communications — to any third party without C&H's prior written consent. This obligation extends to all Argonaut personnel, including senior consultants and research staff who may assist Dr. Brenner in connection with this engagement.
Argonaut's confidentiality obligations under this Section 7 survive the termination of this engagement, regardless of the reason for termination, and shall remain in effect indefinitely.
8. Document Handling and Data Protection
Argonaut will maintain all documents and data received in connection with this engagement — whether in physical or electronic form — in a secure manner, consistent with applicable data protection laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR"). Argonaut will implement appropriate technical and organizational measures to protect the confidentiality, integrity, and availability of such documents and data, and will restrict access to such materials to those Argonaut personnel who have a need to know in connection with this engagement and who are bound by confidentiality obligations consistent with this letter.
Upon termination of the engagement or at C&H's written request, Argonaut will return or securely destroy all confidential documents and data received in connection with this engagement, and will certify such return or destruction in writing to C&H. Argonaut's obligation to return or destroy confidential documents and data is subject to any legal or regulatory retention requirements applicable to Argonaut under German law or other applicable law, provided that Argonaut will continue to maintain the confidentiality of any retained materials in accordance with this letter.
9. Termination
Either party may terminate this engagement upon fifteen (15) days' prior written notice to the other party. Such notice shall be delivered to the contact addresses specified in Section 11 below (or to such other address as a party may designate in writing).
In the event of termination, Argonaut will be compensated for all work performed and all expenses incurred through the effective date of termination, in accordance with the fee arrangements set forth in Section 5. Argonaut will submit a final invoice within thirty (30) days following the effective date of termination.
Upon termination, Argonaut will promptly deliver to C&H all work product completed through the date of termination, including all drafts, memoranda, analyses, reports, notes, and other materials prepared in connection with this engagement, regardless of whether such work product is in final or preliminary form.
The confidentiality and privilege obligations set forth in Sections 7 and 8 above shall survive the termination of this engagement and shall remain in full force and effect.
10. Governing Law
This engagement letter shall be governed by and construed in accordance with the laws of the Federal Republic of Germany, without regard to conflicts-of-law principles that would result in the application of the law of any other jurisdiction.
Any disputes arising out of or relating to this engagement letter, or the breach, termination, or validity thereof, shall be resolved exclusively by the competent courts of Berlin, Germany. Each party hereby consents to the personal jurisdiction and venue of such courts.
11. Points of Contact
The primary points of contact for this engagement are as follows:
Calderwood & Harkness LLP:
Christy Bauer, Senior Associate Intellectual Property & Trade Group
Email: christy.bauer@calderwoodharkness.com
Tel: +32 2 894 7142 (Day-to-day coordination, classification analysis, BTI application)
Garrett Simmons, Associate Tax & Customs Group
Email: garrett.simmons@calderwoodharkness.com
Tel: +32 2 894 7158 (Valuation-related classification issues, duty calculations)
James Prentice, Partner
Email: james.prentice@calderwoodharkness.com
Tel: +32 2 894 7110 (Responsible Partner; to be copied on all substantive communications)
Argonaut Trade Consulting GmbH:
Dr. Lukas Brenner, Managing Director
Email: l.brenner@argonaut-trade.de
Tel: +49 30 2093 4400
All substantive communications, draft work product, and expert materials should be addressed to Christy Bauer, with copies to Garrett Simmons and James Prentice, unless otherwise directed by C&H. Communications may be conducted by email, provided that confidential attachments are transmitted via encrypted file-sharing or secure courier, as appropriate.
12. Acceptance
If the foregoing terms and conditions accurately reflect our mutual understanding regarding Argonaut's engagement, we respectfully request that Dr. Brenner countersign and return a copy of this letter to Christy Bauer at the email address set forth above, thereby confirming Argonaut's acceptance of this retention. A countersigned copy returned by email in PDF format will be accepted as an original for purposes of this engagement.
We look forward to working with you and the Argonaut team on this important matter for our client, and we are confident that your expertise will be invaluable to the resolution of this classification dispute.
Sincerely,
CALDERWOOD & HARKNESS LLP
By: ________
Name: Christy Bauer
Title: Senior Associate
(On behalf of and with the authorization of James Prentice, Partner)
ACCEPTED AND AGREED:
ARGONAUT TRADE CONSULTING GmbH
By: ________
Name: Dr. Lukas Brenner
Title: Managing Director
Date: October 10, 2022
Deliverable | Description | Target Date
Technical Input for BTI Application | Equipment functional descriptions and technical specifications for inclusion in the Technical Annex to BTI application BTI-GR-2022-003847 | November 1, 2022
Preliminary Classification Analysis | Draft memorandum analyzing the CN classification of the STS gantry cranes and ASC systems under the GIRs, Explanatory Notes to the HS and CN, and relevant HS Committee classification opinions | November 15, 2022
Draft Expert Report | Formal expert report suitable for submission to AADE, DG TAXUD, and/or the Administrative Court of First Instance of Piraeus, setting forth Argonaut's independent professional opinion on the correct CN classification | January 15, 2023
Final Expert Report | Finalized expert report incorporating review comments from C&H and prepared for filing | February 15, 2023
Service | Rate
Dr. Lukas Brenner — Expert analysis, report preparation, and consultation | €450 per hour
Senior Consultant support (at Argonaut) | €320 per hour
Research and administrative support (at Argonaut) | €180 per hour
Expert testimony (including preparation time) — Half-day | €5,000 per half-day
Expert testimony (including preparation time) — Full day | €9,000 per full day

PRIVILEGED & CONFIDENTIAL

CALDERWOOD & HARKNESS LLP

ACCEPTED AND AGREED:

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