Omega Navigation Enterprises, Inc.(fka ONAVQ)

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From the docket

8. Importantly, prior to initiating these bankruptcy proceedings, Omega filed two
lawsuit in the Courts of the Hellenic Republic (the "Greece Litigation") against the lenders under
the Senior Facility (the "Senior Lenders"), and Omega reserves its right to seek further damages
or enforce the present lawsuits by the filing of additional suits.
Case 11-35926 Document 9 Filed in TXSB on 07/08/11 Page 4 of 18
HOUSTON\3416970 -5-
9. In the first suit, Omega asserts, among other things, that the Senior Lenders are in
material breach of an agreement whereby they promised to extend the time for repayment of
principal under the Senior Facility for three years from the original due date (i.e. extend to April
12, 2014). The Senior Lenders have not honored their agreement and have refused to extend the
repayment under the Senior Facility. Omega also asserts, among other things, that the Senior
Lenders have engaged in abusive exploitation of the relationship of financial dependence
between the Debtors and the Senior Lenders and such conduct is opposite to the good faith and
contractual ethics required by European standards of competition, and therefore such actions are
invalid. The claims of Omega for abusive exploitation of their dominant position are based on
Article 82 of the European Convention and the related European Commission Regulation
1/2003, which are applicable in Greece, as well as pursuant to Greek Law 703/77.
10. In the second lawsuit, Omega asserts, among other things, that Omega has been
and continues to be seriously damaged by, among other things, the Senior Lenders' breach and
abusive actions. Such damages amount to approximately $570,000,000.00 (plus interest) at the
time of filing the second suit, and, via the second suit, Omega seeks indemnification for such
damages.