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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

CROSS-PETITION FOR CONFIRMATION,
RECOGNITION, AND ENFORCEMENT OF AN ARBITRAL AWARD

Respondent Lion Mexico Consolidated L.P. (“Lion Mexico”) hereby Cross-Petitions for Confirmation, Recognition, and Enforcement of an Arbitral Award (the “Award") pursuant to the Federal Arbitration Act, 9 U.S.C. § 9 and Article IV of the Convention on Recognition and Enforcement of Foreign Arbitral Awards, incorporated into U.S. law by 9 U.S.C. § 201 et seq. The arbitration tribunal was constituted under the International Centre for Settlement of Investment Disputes – Additional Facility Rules, and the Award was issued pursuant to the North American Free Trade Agreement. The Award was issued on September 20, 2021, and became final on that date.

The basis for this Cross-Petition is set forth in the accompanying Memorandum of Law. A proposed order, as well as the declaration of John M. Conlon, have also been filed in support of this Cross-Petition.

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Respectfully submitted,

Dated: February 4, 2022

/s/ Reginald R. Goeke
Reginald R. Goeke (DC Bar No. 435613)
MAYER BROWN LLP
1999 K Street NW
Washington, DC 20006
Tel: +1 (202) 263-3000
[email protected]

John M. Conlon (pro hac vice)
MAYER BROWN LLP
1221 Avenue of the Americas
New York, NY 10020
Tel: +1 (212) 506-2500
[email protected]

Attorneys for Respondent Lion Mexico
Consolidated L.P.