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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Smurfit Holdings B.V.,

Petitioner,

v.

The Bolivarian Republic of Venezuela,

Respondent.

Civil Action No. _________________

Declaration of Matthew S. Rozen in Support of Petition to Enforce Arbitral Award

Pursuant to 28 U.S.C. ยง 1746, I, Matthew S. Rozen, declare as follows:

  1. I am an attorney and am admitted to practice law in the District of Columbia and Virginia. I represent Petitioner Smurfit Holdings, B.V. in this matter.
  2. I am over the age of eighteen and make this declaration from personal knowledge based on information reviewed and/or referenced herein.
  3. This declaration is submitted in support of the Petition to Enforce Arbitral Award filed today by Petitioner.
  4. Attached hereto as Exhibit A is a certified copy of the arbitral award rendered on August 28, 2024 in ICSID Case No. ARB/18/49 in the arbitration proceeding between Petitioner and Respondent, the Bolivarian Republic of Venezuela.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on September 24, 2024
Washington, DC

Signature

Matthew S. Rozen