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IN THE MATTER OF: THE LOEWE GROUP, INC. and RAYMOND L. LOEWE, Claimants/Investors, v. THE UNITED STATES OF AMERICA, Respondent/Party. ISCID Case No. ARB(AF)/98/3 RESPONSE OF THE LOEWE GROUP, INC.

W. Suite 600 Washington, D. C. 2 Ext. 1313 Ext. 1580 Reynolds Dunn & Crutcher LLP 150 West 43rd Street, 9th Floor New York, New York 10017 Telephone: Toll Free: Robert W. Bancroft John B. Puckett Attorney, Chicago JURISDICTION AND COMPETENCE This matter arises under Article 1, Section 8, of the Treaty between the United States of America and Canada, as revised from time to time, and the Mexican Constitution. THE LOEWE GROUP, INC., and Raymond L. Love, the “Plaintiffs,” having filed a first cause of action pursuant to the Treaty, file a second cause of action pursuant to the Treaty, seeking monetary damages for all injunctive and declaratory relief against the Federal Government claiming damages under various provisions, such as the “Treaty and Mexican Constitution” and “the United States Constitution.” The “Respondents,” having filed a third cause of action pursuant to the Treaty, seek monetary damages for injunctive and declaratory relief against the Federal Government asserting damages under various provisions, such as “the Treaty and Mexican Constitution,” “the United States Constitution,” and “the Constitution of the State of Mexico.” WHEREFORE, these plaintiffs demand judgment against the United States as follows: Plaintiffs' demands for declaratory relief. 1. Declaratory relief as to “the Treaty and Mexican Constitution.” The Constitution of Mexico, as amended by the Protocols, incorporates in the Mexican Constitution all the provisions of the Treaty (including Art. 27 of the Treaty), including Art. 2b of the Treaty providing that “no State shall, without the consent of the President of the United States, enter into, or continue in force, an agreement with a foreign power or international organization under which the rights of Mexican nationals are affected.

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The purpose of the Loewen response to article is to provide a formal and official response from the company regarding any inaccurate, misleading, or damaging information published in the article.

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The Loewen response to article should include the specific inaccuracies or misleading information contained in the article, the correct facts or explanations, and any supporting evidence or sources.

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