This document constitutes formal legal notice under Articles 10.15 and 10.16.2 of Chapter 10, Investment, of the United States-Panama Trade Promotion Agreement dated 28 June 2007 (approved by Panama on II July 2007 and by the United States on 21 October 2011),(hereinafter "the FTA,,)l, that a dispute has arisen between the Republic of Panama and the following qualifying United States investors:

• Retire in Chiriqui, S.A.("RIC");

• James Falgout

• Barbara Falgout

• Clarence Johnson (Collectively, herein, "Investors"

Each of the above is an "investor" within the definitions contained in Article 10.29 of Chapter 1 0 of the FTA (and Article I of the BIT) thereby qualifying for protections afforded tmder Article 10 of the same. Please note that this dispute arises out of and relates to the treatment accorded to the Investors by Panama in breach of its treaty obligations tmder the FT A and the BIT as well as Panama's derogation from customary international law, which treatment has caused the Investors to suffer, and to continue to suffer, harm and damages, both material and moral damages.