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Horace Fasttrack<br />

Advocate at the Court<br />

14 Capital Boulevard<br />

Oceanside<br />

Equatoriana<br />

Tel (0) 214 77 32 Telefax (0) 214 77 33<br />

fasttrack@host.eq<br />

31 May 2016<br />

By courier<br />

The President of the Center for Arbitration and Mediation of the Chamber of Commerce Brazil-<br />

Canada (CAM-CCBC)<br />

Rua do Rócio, 220<br />

12º andar - cj.121<br />

São Paulo, SP 04552-000<br />

Brazil<br />

Wright v. SantosD<br />

Request for Arbitration<br />

Pursuant to Article 4.1 CAM-CCBC Rules<br />

Wright Ltd<br />

232 Garrincha Street<br />

Oceanside<br />

Equatoriana<br />

Represented in this arbitration by Horace Fasttrack<br />

SantosD KG<br />

77 Avenida O Rei<br />

Cafucopa<br />

Mediterraneo<br />

- CLAIMANT-<br />

- RESPONDENT-<br />

Statement of Facts<br />

1. Wright Ltd (“Wright”), the CLAIMANT, is a highly specialized manufacturer of fan-blades for<br />

jet engines, incorporated in Equatoriana.<br />

2. SantosD KG (“SantosD”), the RESPONDENT, is a medium sized manufacturer of jet engines,<br />

incorporated in Mediterraneo. Until 2010 CLAIMANT and RESPONDENT were both<br />

subsidiaries of Engineering International SA, a multinational based in Oceania and active in<br />

various fields of engineering, in particular turbines of all sorts. Following the financial crisis<br />

in 2008 and the need to restructure its financing, Engineering International SA divested itself<br />

of several of its previously held subsidiaries to reduce its debts and to concentrate on its core<br />

business. In June 2010 CLAIMANT was sold to CLAIMANT’s present parent company, which<br />

was then renamed Wright Holding PLC. RESPONDENT was sold one month later to SpeedRun,<br />

a Private Equity Fund.<br />

© Association for the Organisation and Promotion of the Willem C. Vis International Commercial Arbitration Moot 3<br />

Prof. Dr. Stefan Kröll

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