UNITED STATES DISTRIC COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 1:18-cv20818-DPG

PDVSA US LITIGATION TRUST

Plaintiff

V.

LUKOIL PAN AMERICAS LLC…

Defendants

AMICUS CURIAE 2

MOTION TO EXERCISE ACCORDING TO THE RULES PRO HAC VICE

AND AMICUS CURIAE

Referring to Case No. 1: 18-cv20818-DPG a claim filed by "US LITIGATION TRUST"

against Lukoil Pan Americas LLC and others in which important interests of my country
the Republic of Venezuela are at stake

I, CARLOS RAMIREZ LOPEZ am a lawyer qualified to practice in the Courts of a

foreign States and According to Rule 6.2 of the Supreme Court of the United States,
effective July 1, 2013, a lawyer qualified to practice in the courts of a foreign State may
be admitted to practice pro hac vice. I have the following qualifications: Specialist in
Civil and Criminal Procedural Law; advanced studies in Constitutional Law (Andrés
Bello Catholic University, Caracas); Diploma in International Criminal Litigation (Alberto
Hurtado University of Chile); Diploma in Human Rights and International Courts,
Impunity and International Justice, Inter-American Human Rights System (American
University Washington College of Law. I am qualified as a trial lawyer since 1972
enrolled in the Bar Associations N0. 8958 in Venezuela.

Rule 6.3 orders that the lawyer who intends to practice under the Pro hac vice form
must indicate concisely the qualifications of the lawyer who will exercise that form of
defense.
AMICUS CURIAE

Based on Rule 37.1 I submit this brief to be considered once the previous motion on Pro
hac vice is decided,, I respectfully want to put before the Court a relevant issue that has
not been put under your knowledge and consideration.

The lawsuit filed in the "Case Nº. 1: 18-cv20818-DPG "is based on the transfer of
litigious rights owned by the Venezuelan State-owned company PDVSA (Petroleos de
Venezuela Sociedad Anonima) State Corporation of Venezuela, a public property that is
expressly alleged in the lawsuit where it is cited thus: "Venezuelan state energy
company Petróleos de Venezuela, SA (PDVSA)" (page 2 "Nature of the action")

The assignment of litigious rights is a contract for the transfer of property belonging to
the state enterprise that as such must be authorized by our Legislative Power (National
Assembly) as established in articles 150 and 187.9 of the Constitution of the Republic of
Venezuela:

"Article 150: The execution of contracts of national public interest shall require the
approval of the National Assembly in cases determined by law."
Article 187.9: "Corresponds to the National Assembly. (9) Authorize the National
Executive to enter into contracts of national interest, in the cases established by law."

The claim has been made by US LITIGATION TRUST of which there is no information
in the file, its constitution or registration document has not been recorded, which is
essential to determine the legality of its action and the quality of the claimant. Only in
the press media the plaintiffs' lawyers have said that the state oil company PDVSA
assigned the collection rights to that trust, but neither in the file has that appropriation
document been assigned to determine the legality of such operation. The plaintiffs
lawyers have told the press that this demand includes the sum of ten billion dollars (US
$ 10,000,000)

Such amount of money could help the people of Venezuela who are suffering all kinds
of needs, hunger and misery, so it should not be accepted that strangers have the
possibility of seizing this capital, and much less in that obscure form with which such
action is intended.
For all mentioned above I respectfully ask this Court as a matter of urgency to:

1.- To please order the plaintiff and its lawyers to consign the aforementioned
documents: assignment of the litigious rights they are claiming and the constitution of
the plaintiff trust.

2.- Notify the Venezuelan Legislative Branch (Asamblea Nacional) so that it formally
intervenes in this case.