I. INTRODUCTION 

A. Preliminary Statement 

1. EuroGas began misrepresenting facts to this Tribunal before it even filed its Memorial, holding itself out to be an entity that it now admits it is not.1 The U.S. judiciary has found that EuroGas and its Director, Wolfgang Rauball, misrepresented facts under oath relevant to this case.2 And a German court has convicted Mr. Rauball for a crime relating to misrepresentations about corporate bankruptcy.3 

2. It should come as no surprise that Claimants continue to misrepresent facts in their Memorial. 

3. When those misrepresentations are exposed, it becomes clear that Claimants’ case is riddled with jurisdictional problems. Claimants have now been forced to admit that the original Claimant in this arbitration, EuroGas Inc. (the company by that name that was incorporated in 1985) (“EuroGas I”), was dissolved in 2001, ceased to have a legal existence when it failed to seek reinstatement within two years, and its assets were liquidated in a U.S. bankruptcy in 2007. 

4. Claimants, however, concealed all of this from the Tribunal. They originally represented to the Tribunal that EuroGas I was the Claimant in this arbitration and owned the alleged investment. When the Slovak Republic caught Claimants in this misrepresentation, Claimants were forced to literally change the identity of the Claimant. The new Claimant is now a different entity that Mr. Rauball incorporated in 2005 (while EuroGas I was in bankruptcy) using the same name, EuroGas Inc. (“EuroGas II”).