PRAYER FOR RELIEF

For the foregoing premises, Aspatria respectfully requests this Honorable Court to:

I. Declare that Rydal, under international law, is not permitted to lawfully take steps giving

effect to the independence of the Islands and must cede administration over the Islands to

Aspatria because:

a. sovereignty over the Islands belongs to Aspatria and

b. the Islanders are not entitled to independence under the principle of self-

determination.

II. Declare that Rydal’s rejection of the MDR bid violated the Aspatria-Rydal Bilateral

Investment Treaty, and

III. Declare that Rydal does not have standing to invoke the Aspatria-Rydal Bilateral

Investment Treaty to protect the assets of ALEC, and in any event, the sequestration of

ALEC’s assets did not violate the Aspatria-Rydal Bilateral Investment Treaty.

Respectfully Submitted,

Agent for Aspatria.