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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MOTION TO INTERVENE

Hector Cardenas respectfully moves this Court for an order granting him leave to intervene as a Petitioner in this action as of right pursuant to Rule 24(a)(2) or, alternatively, permissively pursuant to Rule 24(b)(1)(B). This motion is accompanied by a Memorandum of Law in support thereof, and a Declaration by Mr. Cardenas.

Mr. Cardenas has an interest in the subject of this action, and the Court’s disposition of the case may substantially impair or impede his ability to protect that interest, which is currently not adequately represented by either Lion Mexico Consolidated L.P. (“Lion”) or by the United Mexican States (“Mexico”). Mr. Cardenas’ participation in this action will also aid the Court in its decision on Mexico’s Petition to Vacate Arbitral Award.

Counsel for Mr. Cardenas has conferred with counsel for both Parties. Petitioner Mexico does not oppose this motion. Respondent Lion opposes this motion.

A proposed Order is attached to this Motion.

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WHEREFORE, Mr. Cardenas respectfully requests that the Court grant his leave to participate as intervenor-Petitioner in this case.