Below is a working file from an organisation, followed by 20 questions about it. Some values in the file may have been replaced with markers of the form [REDACTED: ...].

Answer every question using only the information in the file. Do not use tools, other files or the web.
If the file does not give you what you need to answer a question, write CANNOT DETERMINE as the answer to that question.

Reply with exactly 20 lines and nothing else, in this form:
Q1: <answer>
Q2: <answer>
...
Q20: <answer>
Write dates as YYYY-MM-DD.

=== FILE ===

# Case File IL-2025-0417 — Defective renovation claim, post-judgment working file

| Item | Detail |
|---|---|
| Firm | Idaia Legal Partners, Heraklion |
| Client (plaintiff) | Despina Koutsouraki |
| Defendant 1 | Messara Building & Fit-Out S.A. (the "Company") |
| Defendant 2 | Stavros Vergotis (the "Guarantor") |
| Court | Multi-Member Court of First Instance of Heraklion |
| Filing number | 1187/2025 |
| Judgment | No. 412/2026, published 2026-06-05 |
| Responsible partner | Irini Sfakianaki |
| Associate | Manolis Daskalakis |
| Memo status date | 2026-08-12 |

## 1. Purpose of this memo

This file collects everything the firm holds on the renovation claim brought by Ms Koutsouraki against the Company and the Guarantor. It was assembled by Manolis Daskalakis for Irini Sfakianaki after the first-instance judgment was published and served. The partner has asked for one document that answers four practical questions:

1. What exactly did the court award, and how did it compute the figures?
2. Who was served with the judgment, and when?
3. By when must each party appeal, if it wishes to appeal at all?
4. Is an appeal by our client worth its cost, and who would have to be served with it?

The rules of procedure that the firm applies when counting appeal periods are collected in Annex A. They are the only rules used in this file; nothing in the file depends on law that is not written down there. Public holidays for 2026 are in Annex B. The extracts of the deed of guarantee that matter for service are in Annex C, and a summary of the expert report is in Annex D.

## 2. Summary for the partner

The Multi-Member Court of First Instance of Heraklion partly upheld the claim. Of a principal claimed at EUR 49,300 the court awarded EUR 38,180, rejecting the moral damage head entirely and reducing two others. Statutory default interest runs on the awarded principal from 2025-05-05 at 7.25% per annum, and the court charged EUR 3,900 of court costs to the Company alone. The Guarantor was held liable jointly with the Company, but only up to EUR 30,000 of the principal and the interest on that sum, which is the cap written into his deed of guarantee.

Three parties had appeal periods start to run after service, and the three periods are not the same. The Company was served by our bailiff on the date recorded in section 8. Our client was served by the other side, and the Guarantor was served by us; both of those dates are recorded in section 8 as well and must be used with the rules in Annex A. As at the status date no appeal by anybody is on the court registry.

My recommendation, developed in section 9, is that the client should lodge a limited appeal on the rejected heads and the costs, and that the firm should diarise the Guarantor's period as a defensive date, because a late appeal by him on the guarantee would reopen the question of the cap. I also recommend that nobody on the team serves anything on the Guarantor's first-instance lawyer, because her mandate ended with the judgment; the correct person for service is named in Annex C.

## 3. Parties and representatives

| Role | Name | Details held on file |
|---|---|---|
| Client, plaintiff | Despina Koutsouraki | Home address 46 Kalokairinou Street, 71202 Heraklion; tax number 104583927; ID card AK 482913; born 1971-04-12 |
| Defendant 1 | Messara Building & Fit-Out S.A. | Registered seat: Industrial Area of Heraklion, Plot 14; commercial register number 118220327000 |
| Company managing director | Dimitrios Katsanevakis | Signed the building contract for the Company |
| Defendant 2, guarantor | Stavros Vergotis | Address in the deed Lindenweg 12, 80331 Munich, Germany; tax number 127745310; ID card AE 693104; born 1964-11-03 |
| Guarantor's agent for service | Panagiotis Roussos | Office at 42 Panepistimiou Avenue, 10679 Athens; appointed in clause 14 of the deed (Annex C) |
| Our partner | Irini Sfakianaki | Signed the action and all pleadings |
| Our associate | Manolis Daskalakis | Day-to-day conduct; attended hearings 2 to 4 |
| Our paralegal | Eleftheria Mylonaki | Diary and service logistics |
| Company's counsel | Giorgos Kalogeris | Represented the Company at all four hearings |
| Guarantor's counsel at first instance | Kyriaki Louloudaki | Mandate limited to the first-instance proceedings |
| Court-appointed expert | Nikolaos Charalampakis | Civil engineer, appointed on 2026-01-22 |
| Company's site foreman, witness | Kostis Perakis | Gave evidence on the state of the works |
| Bailiff used by the firm | Emmanouil Foukarakis | Served the judgment on the Company and on the Guarantor |
| Bailiff used by the other side | Konstantinos Marakakis | Served the judgment on our client |

The court that decided the case sat as a chamber of three judges: Sofia Mantzourani (President), Antonios Fragiadakis (judge-rapporteur) and Maria Tzanakaki. The court clerk who signed the minutes of all four hearings was Vasiliki Doukaki.

## 4. Background facts

### 4.1 The contract and the guarantee

On 2023-05-10 the client signed a renovation contract with the Company for the refurbishment of her house. The contract price was EUR 71,000 including VAT. The scope covered a roof terrace, two bathrooms, a kitchen, new windows, a new electrical board, interior plaster and paint, floor levelling and external plastering. The Company's managing director, Dimitrios Katsanevakis, signed for the Company. Completion was promised within seven months.

On the same day, 2023-05-10, Stavros Vergotis signed a deed of personal guarantee in favour of the client. He guaranteed the Company's obligations under the contract, including liability for defects and for refund of the price of works not executed, up to a maximum of EUR 30,000 of principal. The deed also contains the clause on service of court documents that is reproduced in Annex C. The Guarantor was, at the time, a shareholder in the Company, which is why the client had asked for the guarantee.

### 4.2 Payments

The client paid the Company EUR 58,000 in three instalments:

| Date | Event | Amount (EUR) |
|---|---|---|
| 2023-05-10 | Advance on signature | 20,000 |
| 2023-08-04 | Second instalment on completion of the structural phase | 25,000 |
| 2023-11-17 | Third instalment on completion of the bathrooms | 13,000 |
| | Total paid | 58,000 |

The remaining EUR 13,000 of the price was withheld by the client when it became clear that the works were defective and incomplete.

### 4.3 The defects and the stoppage

Within weeks of the third instalment the client noticed water infiltration on the roof terrace, misaligned window frames and cracks in the plaster. Our associate visited the house with a private engineer on 2023-12-19 and photographed the condition. On 2024-01-12 the Company's crew left the site and did not return. Three items that had been paid for had not been executed at all: the kitchen cabinets, the bathroom wall tiling in the second bathroom, and the external plaster. The client moved out for the period in which the kitchen and bathrooms could not be used and rented a flat at EUR 650 a month.

The Company's foreman, Kostis Perakis, later told the court that the crew had been withdrawn because the Company was short of materials, not because of any dispute with the client. That evidence helped the client, because it undercut the Company's argument that she had caused the stoppage by withholding the final instalment.

### 4.4 Pre-action steps

On 2024-02-20 the firm sent an extrajudicial notice to the Company and to the Guarantor demanding repair or refund within 30 days. The Company answered on 2024-03-05 through its managing director and rejected liability; the Guarantor did not answer. Both documents are reproduced in section 11. The notice was sent to the registered seat of the Company and to the address for the Guarantor recorded in the deed. No settlement offer was made by either defendant before the action was filed.

## 5. Procedural history

The action was filed on 2025-03-14 and registered as number 1187/2025. It was signed by Irini Sfakianaki. The action claimed four heads of damage (section 6) and invoked the guarantee against the Guarantor for the first two heads and for the accommodation costs. The action was served on both defendants in the months that followed. The court file records valid service on each of them; the date of service on the Company, 2025-05-05, is the date from which the court later awarded interest.

### 5.1 The four hearings

| No. | Date | What happened |
|---|---|---|
| 1 | 2025-10-09 | The case was called but not heard. The court adjourned on its own motion because the roll of the chamber was overloaded. New date: 2026-01-22. |
| 2 | 2026-01-22 | Heard in part. The court found that the technical dispute could not be resolved on the documents and appointed Nikolaos Charalampakis as expert, with a deadline of 2026-03-12 for the report. Adjourned to 2026-03-26. |
| 3 | 2026-03-26 | The expert report had been filed. Counsel for the Company, Giorgos Kalogeris, asked for time so that the Company's technical adviser could answer the report. Over our objection the court granted the request and adjourned to 2026-04-23. |
| 4 | 2026-04-23 | Main hearing. Witnesses heard, including the foreman. The court took the case for decision and gave both sides until 2026-05-07 to file written briefs. |

Between the first hearing and the last, 2025-10-09 to 2026-04-23, the client waited more than six months, and the adjournment requested by the Company at the third hearing added four weeks. Our submission to the court, filed on 2026-05-07 together with the other side's briefs, argued that the expert's unit prices were conservative and should be accepted in full. The Company argued that the roof terrace defect was caused by weather during construction. The Guarantor, through Kyriaki Louloudaki, argued that he could not be liable for defects because the guarantee covered only the refund of money, a point the court rejected.

### 5.2 Publication of the judgment

The judgment, number 412/2026, was published on 2026-06-05, a Friday, forty-three days after the main hearing. The operative part and the reasoning are summarised in sections 6 and 7. A certified copy was collected from the registry by our paralegal, Eleftheria Mylonaki, on the day of publication. Publication does not itself start any appeal period; each period starts only with service on the party concerned, as explained in Annex A.

## 6. The claim and how the court computed the award

### 6.1 Heads of claim, claimed against awarded

| Head | Claimed (EUR) | Awarded (EUR) | Court's reasoning in short |
|---|---|---|---|
| 1. Repair of defects | 31,450 | 27,280 | Expert's net repair cost EUR 22,000 plus 24% VAT of EUR 5,280; the court allowed VAT because the client is a private individual who cannot recover it |
| 2. Refund for works paid but not executed | 8,300 | 8,300 | Kitchen cabinets 3,400; second-bathroom wall tiling 2,750; external plaster 2,150; all three accepted in full |
| 3. Alternative accommodation | 4,550 | 2,600 | Claimed seven months at EUR 650; the court accepted four months, the period in which the kitchen and bathrooms were unusable |
| 4. Moral damage | 5,000 | 0 | Rejected: no basis for non-pecuniary damage in a contract claim of this kind |
| Total principal | 49,300 | 38,180 | |

The gap between claimed and awarded principal is therefore EUR 11,120. Of that, EUR 4,170 comes from the expert's lower repair figure (31,450 against 27,280), EUR 1,950 from the three accommodation months not accepted, and EUR 5,000 from moral damage.

### 6.2 Interest

The court awarded statutory default interest at 7.25% per annum on the awarded principal from 2025-05-05, the date on which the action was served on the Company, until payment in full. The court did not capitalise interest. Interest against the Guarantor runs on the guaranteed part of the principal from the same date.

### 6.3 Court costs

The client had claimed court costs of EUR 9,100. The court allowed EUR 3,900 and charged them to the Company alone. The Guarantor bears no share of the costs. The court explained that the costs allowed correspond to the scale fees for a claim of the awarded value plus the expert's fee, not to the fees actually charged by counsel. The firm's own fee note is in section 12 and is much larger than the costs recovered.

### 6.4 The guarantee

The court held that the guarantee covers refund of the price of works not executed and the cost of repairing defects, so the Guarantor's argument that the deed covers only refunds failed. It then applied the cap in the deed. The Guarantor is liable jointly and severally with the Company for the first EUR 30,000 of the principal, plus interest on that EUR 30,000 from 2025-05-05. For the remaining principal, and for all costs, only the Company is liable.

## 7. Operative part of the judgment

The operative part of judgment No. 412/2026, as read by Sofia Mantzourani for the chamber, contains these orders:

1. The action is upheld in part against the Company and against the Guarantor.
2. The Company is ordered to pay the client EUR 38,180 as principal, with statutory default interest at 7.25% per annum from 2025-05-05 until payment.
3. The Guarantor is ordered to pay, jointly and severally with the Company, the first EUR 30,000 of that principal with interest on that sum from 2025-05-05 until payment.
4. The remainder of the action is rejected, namely the moral damage head, three of the seven accommodation months, and EUR 4,170 of the repair head.
5. Court costs of EUR 3,900 are charged to the Company alone.
6. The judgment is not declared provisionally enforceable.

The judgment runs to 31 pages. The reasoning on the guarantee is at pages 22 to 25, and the reasoning on the expert's figures at pages 14 to 19. The judge-rapporteur, Antonios Fragiadakis, drafted the part on the expert report; Maria Tzanakaki sat as third judge and signed without separate opinion.

## 8. Service of the judgment

None of the parties was served by the court registry. Each party who wants an appeal period to start against another party has to arrange service through a bailiff. Our firm arranged service on the two defendants. The other side arranged service on our client. The returns of service are in tab 14 of the paper file.

| Party served | Arranged by | Bailiff | Date of service |
|---|---|---|---|
| The Company | Our firm | Emmanouil Foukarakis | 2026-06-22 |
| The Guarantor | Our firm | Emmanouil Foukarakis | 2026-07-29 |
| Our client, Despina Koutsouraki | The other side | Konstantinos Marakakis | 2026-07-20 |

The service on the Company took place on a Monday. The Company is a legal person with its registered seat in the Industrial Area of Heraklion, and the firm treats it as resident in Greece for the purpose of the appeal period. The returns for the Guarantor and for our client record the dates shown in the table; the returns are the only evidence the firm relies on for those dates, and nothing in the correspondence in section 11 contradicts them.

Two practical points arise from the returns.

First, the three dates are different, so there are three separate appeal periods. The Company's period and the periods of the two individuals must each be counted from the party's own date of service, with the rules in Annex A.

Second, the date on which the client was served is the only date relevant to the client's own right to appeal. The earlier service on the Company does not shorten or extend the client's period, and neither does the later service on the Guarantor. The partner asked on 2026-08-10 whether the client's period could be said to run from the day the firm collected the certified copy, 2026-06-05; the answer is no, because the firm's collection of the copy is not service on the client.

## 9. Appeal analysis

### 9.1 Which period applies to whom

The length of each period depends on where the appellant resides. Annex A, rule 1, gives the shorter period for an appellant resident in Greece and the longer period for one resident abroad or whose residence is unknown. The residence of each individual party is recorded in the address that appears in section 3. The Company is treated as resident in Greece.

Annex A also explains how to count. A period starts on the day after service. Days from 1 to 31 August are not counted. If the last day is a Saturday, a Sunday or a public holiday, the period ends on the next working day. The holidays for 2026 are listed in Annex B. The firm's paralegal has been asked to enter all three end dates in the diary on that basis, and the end dates are deliberately not repeated in this memo so that the diary remains the single source.

### 9.2 Our client's appeal

The rejected principal is EUR 11,120. It consists of three parts with different prospects:

| Part | Amount (EUR) | Assessed prospect | Weighted value (EUR) |
|---|---|---|---|
| Repair head: expert's unit prices against the claim | 4,170 | 45% | 1,876.50 |
| Accommodation: three further months | 1,950 | 50% | 975.00 |
| Moral damage | 5,000 | 10% | 500.00 |
| Total | 11,120 | | 3,351.50 |

The moral damage head is weak. The court said in terms that a contract claim of this kind gives no room for non-pecuniary damage, and the case law the associate found points the same way. The accommodation head is better, because the court gave no reason for choosing four months rather than seven, and a lack of reasons is a recognised ground of appeal. The repair head depends on whether the appeal court is willing to depart from the expert's net figure, which it rarely does without a second opinion.

An appeal limited to the repair head, the accommodation head and the costs would cost the client about EUR 3,100 in fees according to the firm's quotation of 2026-08-03, plus court stamp. The weighted value of EUR 3,351.50 is close to that cost. The recommendation to appeal therefore rests on two other points: an appeal protects the client's position if the Guarantor appeals, and it gives the client leverage in any settlement discussion about payment of the awarded sum. If the client prefers certainty, the alternative is to accept the judgment and move straight to enforcement against the Company.

### 9.3 The Guarantor's appeal

The Guarantor has every reason to appeal. He lost the argument that the deed covers only refunds, and he is jointly liable for EUR 30,000 of a principal of EUR 38,180. The part of the principal above the cap concerns only the Company. If the Guarantor appeals and wins on the scope of the deed, the client could lose the guarantee for the repair head altogether, which would leave the Company as the only debtor. The Company has been unable to pay its suppliers for months, according to the foreman's evidence. The guarantee is therefore the practical source of recovery, and the firm treats the Guarantor's period as the most important date to watch.

### 9.4 Service of an appeal, and on whom

If the client appeals, the appeal against the guarantee part of the judgment has to be served on the Guarantor. Annex A, rule 7, says that the appeal is served on the respondent in person or on the agent for service that the respondent designated in writing in the underlying contract or deed, and that service on counsel who acted at first instance does not count unless counsel has a fresh mandate. Clause 14 of the deed, reproduced in Annex C, designates an agent for service. The Guarantor's first-instance counsel has already told the firm, in the letter in section 11, that her mandate has ended.

### 9.5 Enforcement

The judgment is not provisionally enforceable. The firm's practice is to wait for the end of each respondent's own period before starting enforcement against that respondent. Enforcement against the Company can therefore be prepared first, since its period starts earliest. The order for payment against the Company has been drafted and is awaiting the partner's signature.

## 10. Timeline

| Date | Event | Source |
|---|---|---|
| 2023-05-10 | Renovation contract signed; deed of guarantee signed; advance of EUR 20,000 paid | Contract; Annex C |
| 2023-08-04 | Second instalment of EUR 25,000 paid | Section 4.2 |
| 2023-11-17 | Third instalment of EUR 13,000 paid | Section 4.2 |
| 2023-12-19 | Site visit with private engineer; defects photographed | File note |
| 2024-01-12 | Company's crew leaves the site | Section 4.3 |
| 2024-02-20 | Extrajudicial notice to Company and Guarantor | Section 11, item 1 |
| 2024-03-05 | Company rejects liability | Section 11, item 2 |
| 2025-03-14 | Action filed, number 1187/2025 | Section 5 |
| 2025-05-05 | Action served on the Company; interest start date | Section 6.2 |
| 2025-10-09 | First hearing; adjourned by the court to 2026-01-22 | Section 5.1 |
| 2026-01-22 | Second hearing; expert appointed; adjourned to 2026-03-26 | Section 5.1 |
| 2026-03-12 | Expert report filed | Annex D |
| 2026-03-26 | Third hearing; adjourned at the Company's request to 2026-04-23 | Section 5.1 |
| 2026-04-23 | Main hearing; case taken for decision | Section 5.1 |
| 2026-05-07 | Written briefs filed by all parties | Section 5.1 |
| 2026-06-05 | Judgment No. 412/2026 published; certified copy collected | Section 5.2 |
| 2026-06-22 | Judgment served on the Company | Section 8 |
| 2026-07-20 | Judgment served on our client by the other side | Section 8 |
| 2026-07-29 | Judgment served on the Guarantor by our firm | Section 8 |
| 2026-08-03 | Quotation for a limited appeal sent to the client | Section 11, item 8 |
| 2026-08-10 | Appeals registry searched: no appeal on file | File note |
| 2026-08-12 | Status date of this memo | |

## 11. Correspondence

The items below are kept in the order of their dates. Item numbers are used elsewhere in this file.

### Item 1 — Extrajudicial notice, 2024-02-20

From: Idaia Legal Partners, signed Irini Sfakianaki
To: Messara Building & Fit-Out S.A., attention of Dimitrios Katsanevakis, Industrial Area of Heraklion, Plot 14; and Stavros Vergotis, Lindenweg 12, 80331 Munich, Germany

Dear Sirs,

We act for Ms Koutsouraki. Under the renovation contract of 2023-05-10 the Company undertook to complete the refurbishment of our client's house within seven months. Our client has paid EUR 58,000. The Company's crew left the site on 2024-01-12. The roof terrace leaks, the window frames are misaligned, the plaster is cracked, and three items that were paid for have not been executed: the kitchen cabinets, the wall tiling of the second bathroom and the external plaster.

We call on the Company to repair the defects and to complete or refund the unexecuted items within thirty days of receipt of this notice. We call on Mr Vergotis to confirm that he will honour his deed of guarantee of 2023-05-10 if the Company does not perform. If we have no satisfactory reply we have instructions to file an action without further notice.

Yours faithfully,
Irini Sfakianaki, Idaia Legal Partners

### Item 2 — Reply of the Company, 2024-03-05

From: Dimitrios Katsanevakis, managing director, Messara Building & Fit-Out S.A.
To: Idaia Legal Partners

Dear Colleague,

We have received your notice. The Company rejects it. The works were interrupted because your client refused to pay the final instalment, which was due. The alleged defects are normal settlement of a new structure and do not affect the use of the house. The three items you list were either executed or replaced by equivalent work agreed orally with our site foreman. We are prepared to meet your client on site, but we will not pay any sum. Please direct any further correspondence to our counsel, Giorgos Kalogeris.

Yours,
Dimitrios Katsanevakis

### Item 3 — Advice to the client before filing, 2025-02-10

From: Manolis Daskalakis
To: Ms Koutsouraki

Dear Ms Koutsouraki,

As discussed, we propose to file the action in the Multi-Member Court of First Instance of Heraklion, because the claim exceeds the value that a single judge may decide and because the works were carried out in the court's district. We will claim four heads: the cost of repair, refund of the price of the unexecuted items, the cost of your alternative accommodation, and moral damage. We recommend a court-appointed expert, because the other side disputes that any defect exists. Our estimate is a first-instance judgment within about eighteen months from filing, though the court's roll is long and adjournments are common.

Our fixed fee for the preparation and filing of the action is EUR 2,400 plus VAT, as agreed in the engagement letter. Please send us your tax number and a copy of your ID card for the court file.

Kind regards,
Manolis Daskalakis

### Item 4 — Note to the client after the second hearing, 2026-01-23

From: Manolis Daskalakis
To: Ms Koutsouraki

The second hearing took place yesterday. The court agreed with us that the technical dispute needs an expert and appointed Nikolaos Charalampakis, a civil engineer. He has until 2026-03-12 to file his report and will want to visit the house. Please arrange access for him and keep the original photographs from 2023. The court adjourned to 2026-03-26. Your advance payment towards the expert's fee, EUR 600, is included in the disbursements on the fee note.

### Item 5 — Expert's cover note to the parties, 2026-03-13

From: Nikolaos Charalampakis, civil engineer
To: The parties' counsel

I enclose my report, which was filed with the registry on 2026-03-12. I inspected the house on two dates and measured the leaks on the roof terrace after a rain simulation. My conclusion is that the six defects listed in the report are due to poor workmanship, that the net cost of repair at current unit prices is EUR 22,000, and that three paid items were not executed at all, to a total value of EUR 8,300. I do not find that any defect is caused by settlement of the structure. I am available to answer written questions until the next hearing.

### Item 6 — Letter of the Company's counsel, 2026-03-27

From: Giorgos Kalogeris
To: Irini Sfakianaki

Dear Colleague,

Further to the hearing of yesterday, I confirm that the court granted my client until the adjourned date to file technical observations on the expert report. My client's technical adviser will inspect the house; please confirm that your client will allow access on a weekday of your choosing next week. My client does not accept the expert's conclusion on the roof terrace and reserves all rights.

Yours faithfully,
Giorgos Kalogeris

### Item 7 — Note to the client on publication, 2026-06-05

From: Irini Sfakianaki
To: Ms Koutsouraki

The court has published its judgment today and our paralegal has collected a certified copy. In short: the claim succeeds in part. You are awarded EUR 38,180 with interest, and the Company must pay EUR 3,900 of costs. Mr Vergotis is liable with the Company for the first EUR 30,000. The court rejected moral damage and reduced two other heads. Please do not discuss the judgment with the other side. No appeal period starts until somebody is served, and we will tell you when that happens.

### Item 8 — Quotation for a limited appeal, 2026-08-03

From: Irini Sfakianaki
To: Ms Koutsouraki

You asked what an appeal would cost. A limited appeal on the repair head, the accommodation head and the costs would cost EUR 3,100 in fees plus the court stamp. We estimate that the weighted value of what you could gain is about EUR 3,350, so the decision is finely balanced; our full assessment will follow in a memo to the partner. Please let us have your decision soon, so that the appeal can be prepared and filed without any pressure. The date by which the appeal has to be filed is entered in our diary and we will confirm it to you by telephone, not by e-mail.

### Item 9 — Letter of the Guarantor's first-instance counsel, 2026-08-04

From: Kyriaki Louloudaki
To: Idaia Legal Partners, attention of Manolis Daskalakis

Dear Colleague,

I act, or rather acted, for Mr Vergotis at first instance. My mandate was limited to the proceedings before the Multi-Member Court of First Instance of Heraklion and ended when the judgment was published. I have no instructions for any appeal and I am not authorised to accept service of any appeal, cross-appeal or enforcement document on my former client's behalf. Please do not serve anything on this office. I understand that under the deed of guarantee, court documents for Mr Vergotis are to be served at the office of the agent named in the deed.

Yours sincerely,
Kyriaki Louloudaki

### Item 10 — Reply of the client, 2026-08-05

From: Ms Despina Koutsouraki
To: Manolis Daskalakis

Thank you for the quotation. I am a little confused by the dates. The bailiff of the other side handed me the envelope with the judgment at my front door on 2026-07-20, and I understood from our earlier conversation that the clock only starts with service. Please tell me, by telephone, the last day on which I can file. I would also like to understand why the three of us seem to have different dates, because I thought the judgment was the same for everyone. I will be reachable on my mobile all August.

Regards,
Despina Koutsouraki

### Item 11 — Internal instruction of the partner, 2026-08-11

From: Irini Sfakianaki
To: Eleftheria Mylonaki, Manolis Daskalakis

Please enter three end dates in the diary: the Company's, our client's and Mr Vergotis's. Compute each from its own date of service in tab 14 using the firm's rules in Annex A, and have the second lawyer check the count. Remember that the August rule applies, and remember that a date that falls on a Saturday, a Sunday or one of the holidays in Annex B moves forward. Do not write the computed dates in any e-mail; give them to the client by telephone. Repeat the appeals registry search each week; if it ever shows that any appeal has been lodged, tell me at once.

## 12. Fee note

Fee note No. 2026/118 for the first-instance proceedings, issued on 2026-06-10.

Billed to: Despina Koutsouraki, 46 Kalokairinou Street, 71202 Heraklion, tax number 104583927.

| No. | Description | Basis | Amount (EUR) |
|---|---|---|---|
| 1 | Preparation and filing of the action | Fixed fee under the engagement letter | 2,400.00 |
| 2 | Attendance at four hearings | 4 hearings at EUR 450.00 | 1,800.00 |
| 3 | Review of the expert report and meetings with the technical adviser | 6.5 hours at EUR 120.00 | 780.00 |
| 4 | Written brief after the main hearing | Fixed fee | 1,250.00 |
| | Subtotal of fees | | 6,230.00 |
| | VAT at 24% on fees | | 1,495.20 |
| 5 | Expert's fee advance paid on the client's behalf | No VAT | 600.00 |
| 6 | Court stamp and filing charges paid on the client's behalf | No VAT | 560.00 |
| | Total of fee note | | 8,885.20 |

The fee note does not include the cost of a possible appeal or of enforcement. Those would be billed separately under the quotation in section 11, item 8. The court costs of EUR 3,900 awarded by the judgment are payable by the Company to the client; they are not set off against this fee note and will be credited to the client's account only when they are actually collected.

Payment received to date: EUR 2,976.00 on account, paid on 2025-03-12. The balance of the fee note is payable within thirty days of the client's instruction to enforce or to appeal, whichever is earlier, under the engagement letter.

## Annex A — Rules applied in this file

These are the rules that the firm applies when it computes appeal periods in this file. Every end date in the file must follow from them.

1. **Length of the appeal period (Code of Civil Procedure, Art. 518(1)).** An appeal against a first-instance judgment must be filed within 30 days of service of the judgment if the appellant resides in Greece, and within 60 days of service if the appellant resides abroad or the residence is unknown. For an individual, residence is taken from the address recorded for that individual in the party table in section 3 of this file or in the deed. A company is resident at its registered seat.
2. **Judgment never served (Art. 518(2)).** If the judgment was never served on the party concerned, the appeal period is two years from publication of the judgment. In this file the two-year period ends on the same calendar date two years after the date of publication. The August rule in point 3 is not applied to the two-year period. The weekend and holiday rule in point 5 is applied to it.
3. **August suspension (Art. 147(2)).** The period from 1 August to 31 August (both days included) suspends the 30-day and 60-day periods. Days from 1 to 31 August are not counted. Counting stops on 31 July and resumes on 1 September.
4. **Start of the period.** A period starts on the day after service. The day of service itself is not counted. The first counted day is the day after service, unless that day falls in August, in which case counting begins on 1 September.
5. **Weekends and holidays.** If the last day of a period is a Saturday, a Sunday or a public holiday, the period ends on the next working day, meaning the next day that is not a Saturday, a Sunday or a public holiday. A weekend or a holiday in the middle of a period does not extend it; the rule only matters for the last day. Apply the August rule first, and apply this rule to the day that results.
6. **Counting method.** To compute an end date, number the counted days one by one: the first counted day is day 1 and the last counted day is day 30 (or day 60). Do not add a calendar month to a date.
7. **Service of an appeal.** An appeal is served on the respondent in person, or on the agent for service that the respondent designated in writing in the underlying contract or deed. Service on counsel who represented the respondent at first instance does not count as service of the appeal unless that counsel holds a fresh mandate for the appeal.
8. **Worked examples.** These examples use dates that have nothing to do with this case. (a) A judgment served on 2026-06-24 on a party resident in Greece starts counting on 2026-06-25; June provides six counted days (25 to 30 June), July provides the other 24, so day 30 is 2026-07-24, a Friday, and that is the last day. (b) A judgment served on 2026-07-27 on a party resident in Greece starts counting on 2026-07-28; July provides four counted days (28, 29, 30 and 31 July); August is skipped; counting resumes on 2026-09-01 and day 30 is 2026-09-26, a Saturday, so the last day moves to Monday 2026-09-28.

## Annex B — Public holidays in Greece, 2026

Orthodox Easter Sunday in 2026 falls on 2026-04-12. Clean Monday is 48 days before Easter, on 2026-02-23. Whit Monday is 50 days after Easter, on 2026-06-01. The fixed holidays are the ordinary national holidays.

| Date | Weekday | Holiday |
|---|---|---|
| 2026-01-01 | Thursday | New Year's Day |
| 2026-01-06 | Tuesday | Epiphany |
| 2026-02-23 | Monday | Clean Monday |
| 2026-03-25 | Wednesday | Annunciation and Independence Day |
| 2026-04-10 | Friday | Good Friday |
| 2026-04-12 | Sunday | Easter Sunday |
| 2026-04-13 | Monday | Easter Monday |
| 2026-05-01 | Friday | Labour Day |
| 2026-06-01 | Monday | Whit Monday |
| 2026-08-15 | Saturday | Dormition of the Virgin Mary |
| 2026-10-28 | Wednesday | Ochi Day |
| 2026-12-25 | Friday | Christmas Day |
| 2026-12-26 | Saturday | Second day of Christmas |

From June to December 2026 the holidays are therefore 1 June, 15 August, 28 October, 25 December and 26 December. No other day in those months is treated as a public holiday in this file. The suspension for August in Annex A, point 3, covers 15 August in any case.

## Annex C — Extracts of the deed of guarantee

Deed of personal guarantee signed on 2023-05-10 between Despina Koutsouraki as beneficiary and Stavros Vergotis as guarantor.

**Clause 1 — Guarantor.** The guarantor is Stavros Vergotis, born 1964-11-03, holder of ID card AE 693104 and of tax number 127745310, of Lindenweg 12, 80331 Munich, Germany.

**Clause 2 — Beneficiary.** The beneficiary is Despina Koutsouraki, born 1971-04-12, holder of ID card AK 482913 and of tax number 104583927, of 46 Kalokairinou Street, 71202 Heraklion.

**Clause 3 — Guaranteed obligations.** The guarantor guarantees the performance by Messara Building & Fit-Out S.A. of its obligations under the renovation contract of the same date, including its liability for defects and for refund of the price of works paid but not executed.

**Clause 4 — Cap.** The guarantor's liability is limited to a maximum of EUR 30,000 of principal, to which interest on that sum is added. The guarantor owes no share of costs unless he is ordered to pay costs personally by a court.

**Clause 9 — Nature of liability.** The guarantor is jointly and severally liable with the Company up to the cap in clause 4 and waives the benefit of discussion and the benefit of division.

**Clause 14 — Agent for service.** The guarantor appoints Panagiotis Roussos, whose office is at 42 Panepistimiou Avenue, 10679 Athens, as his agent for service of all judicial and extrajudicial documents in Greece, including summonses, judgments and appeals. Service at the agent's office is valid service on the guarantor. The appointment lasts until all guaranteed obligations are discharged and can be changed only by written notice to the beneficiary. The appointment is not limited to any particular proceeding or to any court instance.

## Annex D — Summary of the expert report

The report of Nikolaos Charalampakis was filed on 2026-03-12 and runs to 47 pages. The expert inspected the house on two dates and used current regional unit prices.

| No. | Defect | Cause found | Net repair cost (EUR) |
|---|---|---|---|
| 1 | Roof terrace waterproofing failed | Membrane laid on wet substrate | 6,400 |
| 2 | First bathroom waterproofing and re-tiling | Missing waterproof layer | 4,900 |
| 3 | Window frames misaligned | Poor installation | 3,200 |
| 4 | Electrical board non-compliant | Wrong breakers and no earthing | 2,100 |
| 5 | Interior plaster cracks and repainting | Plaster applied too thick in one coat | 3,300 |
| 6 | Floor levelling | Screed out of tolerance | 2,100 |
| | Net repair cost | | 22,000 |
| | VAT at 24% | | 5,280 |
| | Repair cost including VAT | | 27,280 |

Items paid for but not executed, by the expert's valuation of the contract schedule:

| Item | Value (EUR) |
|---|---|
| Kitchen cabinets | 3,400 |
| Wall tiling of the second bathroom | 2,750 |
| External plaster | 2,150 |
| Total | 8,300 |

The expert did not find that any of the six defects could be explained by weather during construction or by settlement of the structure. He accepted that the roof terrace failure was aggravated by rain in the weeks after installation, but he held that a competent contractor would have protected the membrane.

=== QUESTIONS ===

Q1: What is the last day for our client to file an appeal against judgment No. 412/2026?
Q2: What is the last day for the Guarantor to file an appeal against judgment No. 412/2026?
Q3: What is the last day for the Company to file an appeal against judgment No. 412/2026?
Q4: To whom (name) must an appeal by our client against the guarantee part of the judgment be served?
Q5: What total did the court award against the Company in principal and costs, excluding interest?
Q6: In which country does the Guarantor reside?
Q7: How many days lie between the interest start date and the publication of the judgment?
Q8: How many days after the publication of the judgment was our client served with it?
Q9: To what date was the hearing adjourned at which the Company asked for time to answer the expert report?
Q10: On which weekday was the judgment served on the Guarantor?
Q11: How much of the awarded principal lies above the Guarantor's cap?
Q12: On what date does the counting of the Guarantor's appeal period begin?
Q13: If the judgment had never been served on anyone, what would be the last day to appeal under the firm's rules?
Q14: As at the memo's status date, how many days of our client's appeal period remain unused?
Q15: On which weekday would our client's appeal period end before the weekend and holiday rule is applied?
Q16: How many days passed between the filing of the action and the first fixed hearing?
Q17: How many days after the Company's last day to appeal does our client's last day to appeal fall?
Q18: By how much does the total of the fee note exceed the court costs awarded?
Q19: Whose last day to appeal falls first, our client's or the Guarantor's?
Q20: How many days after service on our client was the judgment served on the Guarantor?
