I. INTRODUCTION

1. Pursuant to Article 2(1) of Schedule C - Arbitration (Additional Facility) Rules of the ICSID Additional Facility Rules ("Rules"), Claimant Corona Materials, LLC ("Corona Materials") submits this Request for Arbitration ("Request") against Respondent Dominican Republic ("DR").

2. In accordance with Article 3(3) of the Rules, Corona Materials submits five additional signed copies of this Request and has wired the $25,000 registration fee prescribed by Regulation 16 ofiCSID's Administrative and Financial Regulations.

II. PARTIES TO THE DISPUTE

A. Claimant Corona Materials, LLC

3. Corona Materials is a limited liability company that was formed under the laws of the U.S. State of Florida in November of 2005. A true and correct copy of Corona Materials' corporate registration with the U.S. State of Florida is attached hereto as Exhibit I.

4. Corona Materials is a juridical person and pursuant to Article 3(l)(e) of the Rules, it has taken all necessary internal actions to authorize this Request. A true and correct copy of the confirmation authorizing this Request is attached hereto as Exhibit 2.