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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

JOINT CONSENT MOTION TO STAY PROCEEDINGS

Petitioner Clorox Spain S.L. (“Petitioner”) and Respondent the Bolivarian Republic of Venezuela ("Respondent” or the “Republic,” and together with Petitioner, the “Parties”), by and through their undersigned counsel, respectfully move this Court to stay all proceedings in the above-captioned action pending the occurrence of a confidential condition precedent set forth in the Parties' Conditional Partial Settlement Agreement (the “Settlement Agreement”). In support of this Motion, the Parties state as follows:

Petitioner commenced arbitration proceedings against Respondent pursuant to Article XI of the Agreement Between the Kingdom of Spain and the Republic on the Reciprocal Promotion and Protection of Investments under the 2010 UNCITRAL Arbitration Rules, administered by the Permanent Court of Arbitration, with the legal seat of arbitration in Geneva, Switzerland. Pet. to Enforce Arbitration Award 7, ECF No. 1. On August 9, 2023, the arbitral tribunal issued a final award in favor of Petitioner (the “Award”). Id. at 8. Respondent sought to annul the Award before the Swiss Federal Supreme Court, which rejected the annulment on April 26, 2024. Id. at 10.

On July 16, 2024, Petitioner filed this action in the United States District Court for the District of Columbia seeking recognition and enforcement of the Award pursuant to the

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Convention on the Recognition and Enforcement of Foreign Arbitral Awards of June 10, 1958 and the Federal Arbitration Act, 9 U.S.C. §§ 201–08. See id.

The Parties have agreed in principle to a conditional partial settlement of Petitioner's claims in this action. The specific terms of the Parties' agreement depend in part on the outcome of ongoing litigation on appeal. Should the appellate court presiding over the related litigation affirm the lower court's decision, the Parties have agreed to file a stipulation of judgment confirming Petitioner's Award in this case. To conserve judicial resources and avoid unnecessary litigation while the Parties await the resolution of the appeal of that related litigation, the Parties jointly and respectfully request that the Court stay all deadlines and proceedings in this case. With the Court's permission, the Parties will provide an update to the Court on the status of the Parties' conditional partial settlement within three months of this Court's entry of the order staying this case.

A stay is within the power of this Court, serves judicial economy, and is agreed upon by the Parties. Accordingly, Petitioner and Respondent respectfully request that the Court enter the accompanying Proposed Order and stay these proceedings.

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Dated: December 10, 2025