Summary

PETITION TO CONFIRM INTERNATIONAL ARBITRATION AWARD - DIS Case No DIS-SV-2024-01079

Petitioner Raisin Bank AG ("RSB" or "Petitioner") files this petition to confirm the international arbitration final award entered in RSB's favor on June 29, 2026 ("Final Award"), as corrected by the Arbitral Tribunal's Correction of the Final Award dated August 11, 2026 ("Corrected Award"), against Tesspay Finance Inc. ("Tesspay" or "Respondent 1") and Jeffrey F. Mason ("Mason" or "Respondent 2") (and, together with Tesspay, "Respondents") and in support alleges as follows:

I. PRELIMINARY INTRODUCTION

1. RSB seeks recognition of a final foreign arbitration award under the New York Convention. The Final Award was entered in RSB's favor by a validly constituted arbitral tribunal seated in Frankfurt am Main, Germany, following an arbitration in which Respondents were given full notice, appeared, and participated. Respondents have not paid the Final Award and, so far as the record shows, have not moved to set aside or suspend the Final Award in any jurisdiction. None of the grounds to deny or delay recognition under the New York Convention are met in this case. Accordingly, the Final Award should be summarily confirmed.

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The Final Award, as corrected by the Corrected Award, orders Respondents, jointly and severally (except as otherwise noted), to pay RSB a total in excess of EUR 3.5 million, including: (i) EUR 2,512,052.47 plus EUR 214,696.06 in interest under the Partial Settlement Agreement; (ii) EUR 845,494.62 plus interest at five percentage points ...