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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

HYDRO ENERGY 1, S.À.R.L.; and
HYDROXANA SWEDEN AB,

Petitioners,

v.

KINGDOM OF SPAIN,

Respondent.

Civil Action No. 1:21-cv-02463-RJL

THE KINGDOM OF SPAIN'S MOTION TO DISMISS THE PETITION
OR STAY THE PROCEEDING

The Kingdom of Spain moves to dismiss the Petition pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). In the alternative, Spain requests at a minimum that these proceedings be stayed until its application to an ICSID ad hoc committee for annulment of the Award is resolved. The bases for this motion are set forth in the Memorandum of Law filed herewith. Spain respectfully requests oral argument on its motion pursuant to Local Rule 7(f).

Respectfully submitted,

/s/ Ana C. Reyes

Ana C. Reyes (D.C. Bar No. 477354)
Jonathan M. Landy (D.C. Bar No. 467847)
Benjamin W. Graham (D.C. Bar No. 1044724)
WILLIAMS & CONNOLLY LLP
725 Twelfth Street, N.W.
Washington, DC 20005
Tel: (202) 434-5000
Fax: (202) 434-5029
Email: [email protected]

Csaba M. Rusznak (D.C. Bar No. 1030310)
SOVEREIGN ARBITRATION ADVISORS LLC
1050 Connecticut Avenue, N.W., Ste. 66255

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Washington, DC 20035
[email protected]

Counsel for the Kingdom of Spain

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CERTIFICATE OF SERVICE

I hereby certify that on February 24, 2022, I caused the foregoing to be filed electronically with the Clerk of Court using the CM/ECF system, which will send notification of such filing to all registered participants.

/s/ Ana C. Reyes
Ana C. Reyes