A. OVERVIEW OF THE CLAIM

1. This is a case about governance gone very wrong. It involves basic unfairness and abuse of the land use planning and licensing approval process by self-interested political insiders who used unfair, non-transparent and 'secret regulatory procedures to circumvent the standard approval process and then prevent their victim from being able to obtain any meaningful independent review of outrageous governmental measures.

2. The victim of this unfair behavior was St. Marys Cement Inc. (Canada) (USMC"), a Canadian Investment that is owned and controlled by Sl. Marys VCNA, LLC, a Delaware company, the Investor.

3. The Votorantim Cement North America Group of Companies, which include both the Investor and Investment, has almost 1200 employees in Canada and another 1700 in the United States. It is well-known that the Investment (and the Investor) is ultimately owned by a foreign entity and is part of the Votorantim Group of BraziL The Investment, SMC, was founded in ] 9] 2 and has been in operation in Canada for nearly one hundred years. SMC owns a variety of US cement, aggregate and concrete supply companies with operations located in ten US states.