Order | Filed: November 06, 2025
| Entered: November 06, 2025
HB Strategies LLC v. The Bolivarian Republic of Venezuela
Contract: Other | New York Southern
Stipulation and Order of Dismissal
JOINT STIPULATION AND ORDER OF DISMISSAL WITHOUT PREJUDICE: IT IS HEREBY STIPULATED by the Parties, through their undersigned counsel, as follows: 1.This Action shall be dismissed without prejudice. 2.Any claims as to which the applicable statute of limitations has not run as of the date of the Tolling Resolution (August 11, 2023) with respect to the Bonds listed in the Complaint, that are re-filed on or before December 31, 2028, ("Re-filed Claims," and any action asserting Re-filed Claims, a Re-filed Action) shall be deemed timely filed. 3. The Republic promises not to plead the statute of limitation as to any Re-filed Claim asserted in any Re-filed Action, provided such Re-filed Claim is asserted on or before December 31, 2028 in a Re-filed Action commenced in this Court or the New York County Supreme Court on or before December 31, 2028. Should the Republic extend the statute of limitations applicable to an action on the Bonds to a date after December 31, 2028 by law, resolution, or otherwise, the Republic promises not to plead the statute of limitation as to any Re-filed Claim asserted in any Re-filed Action, provided such Re-filed Claim is asserted on or before the extended statute of limitations deadline specified by the Republic. 4. The Republic acknowledges that any claims as to which the applicable statute of limitations has not run as of the date of the Tolling Resolution (August 11, 2023) with respect to any other 7.0% 2018 bonds, CUSIP No. P97475AD2 issued by Republic that are hereafter acquired by Plaintiff (the "Additional Bonds") that are filed by Plaintiff or Plaintiff's assignees or transferees on or before December 31, 2028 (the "Newly-Filed Claims," and any action asserting Newly-filed Claims, a "Newly-filed Action") shall be deemed timely filed. Similarly, should the Republic extend the statute of limitations applicable to an action on the Additional Bonds to a date after December 31, 2028 by law, resolution, or otherwise, the Republic promises not to plead the statute of limitation as to any Newly-filed Claim asserted in any Newly-filed Action, provided such Newly-filed Claim is asserted on or before the extended statute of limitations deadline specified by the Republic, as further set forth herein. 10. Each Party in this Action shall bear its own costs. None of the Parties is an infant, incompetent person for whom a committee has been appointed, or conservatee. Pursuant to General License No. 42, the Republic is authorized to enter into this Stipulation. 11. This dismissal shall not be counted for purposes of Fed. R. Civ. P. 41(a)(1)(B) or N.Y. CPLR § 3217(c). 12. The undersigned are authorized to enter into this Stipulation on behalf of their respective clients. 13. This Stipulation may be signed in counterparts, and facsimile and electronic signatures shall be deemed as original. SO ORDERED. (Signed by Judge Analisa Torres on 11/6/2025) (vfr)