Pursuant to Articles 2 and 4 of the Additional Facility Rules, Articles 2 and 3 of the Arbitration (Additional Facility) Rules (“Arbitration Rules”), and Articles 1116, 1117, and 1120(1)(b) of the North American Free Trade Agreement (“NAFTA”), Mercer International Inc. (“Mercer”), hereby respectfully requests approval of access to the Additional Facility and institution of arbitration proceedings concerning the claims discussed herein. Mercer submits this Request for Arbitration both under NAFTA Article 1116 (on its own behalf), and under Article 1117 (on behalf of Mercer’s wholly-owned Canadian subsidiary, Zellstoff Celgar Limited, hereafter “Celgar”). In accordance with Article 3 of the Arbitration Rules, this Request is accompanied by five additional signed copies and the $25,000 lodging fee prescribed by Administrative and Financial Regulation 16.1