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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

RESPONDENT THE REPUBLIC OF COLOMBIA’S MOTION TO DISMISS
FOR LACK OF JURISDICTION
OR IN THE ALTERNATIVE TO STAY THE PROCEEDINGS

Pursuant to Rules 12(b)(1) and (2) of the Federal Rules of Civil Procedure, Respondent the Republic of Colombia (“the Republic” or “Colombia”) moves to dismiss the Petition to Recognize and Enforce a Foreign Arbitral Award (the “Petition”) filed by Telefónica, S.A. (“Petitioner”), for lack of personal and subject matter jurisdiction under the Foreign Sovereign Immunities Act (“FSIA”), 28 U.S.C. §§ 1330, 1602 et seq. In the alternative, the Republic requests an order staying these proceedings, pursuant to the Court’s inherent authority, pending the outcome of the annulment proceeding in Telefónica, S.A. v. Republic of Colombia, ICSID Case No. ARB/18/3, before the ad hoc Annulment Committee constituted under Article 52 of the Convention on the Settlement of Investment Disputes Between States and Nationals of Other States (“ICSID Convention”).

Service of the Petition and Summons on the Republic was completed on July 9, 2026, pursuant to the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents and 28 U.S.C. § 1608(a)(2). See Return of Service/Affidavit of Summons and Complaint (August

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21, 2026). This Motion is timely filed within the sixty (60) days provided under 28 U.S.C. § 1608(d).

Pursuant to Local Civil Rule 7(f), the Republic respectfully requests that the Court schedule an oral hearing on its motion.

Pursuant to Local Civil Rule 7(m), counsel for the Republic has conferred with counsel for Petitioner with respect to the alternative request for a stay, and has confirmed that Plaintiff opposes this motion.

This motion is based upon the accompanying Memorandum of Points and Authorities in Support of the Republic of Colombia’s Motion to Dismiss for Lack of Jurisdiction or in the Alternative to Stay Proceedings, and Declaration of David M. Bigge and exhibits filed concurrently herewith.

Dated: September 8, 2026

Respectfully submitted,

WORDSTONE DISPUTE RESOLUTION US LLP

By: /s/ David M. Bigge

David M. Bigge
D.C. Bar No. 994194
1320 19^th Street, NW
Suite 600
Washington, D.C. 20036
Tel.: +1 202 902 1801
Email: [email protected]

Attorneys for Respondent
The Republic of Colombia