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UNITED STATES DISTRICT COURT
DISTRICT OF COLUMBIA

NOTICE OF SETTLEMENT

Plaintiff Lupaka Gold Corp. (“Lupaka”) respectfully notifies the Court that the parties have agreed to payment terms to resolve this matter and requests that the Court take no further action in this proceeding pending Defendant Republic of Peru’s (“Peru’s”) compliance with those agreed terms.

Lupaka commenced this action against Peru on February 27, 2026, to recognize and enforce an arbitral award issued by the International Centre for Settlement of Investment Disputes. Dkt. 1. On April 6, 2026, this Court granted Lupaka’s Motion for Issuance of a Letter Rogatory to enable Lupaka to serve Peru under the Inter-American Convention on Letters Rogatory and its Additional Protocol. Dkt. 6. That service has not been completed.

The parties have now agreed on payment terms that would fully resolve this dispute by December 31, 2026. Once Peru satisfies its payment obligations under those terms, Lupaka anticipates filing a notice of voluntary dismissal terminating this action with prejudice. In the meantime, Lupaka respectfully requests that the Court take no further action in this matter. Lupaka will promptly notify the Court if circumstances develop that require action from the Court.

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We thank the Court for its time and attention to this matter.