In our capacity as representative for Axel Brandenburg, we are hereby allowed to file the following reply in headings
goal against Villa Europa Sp. z o. o. (hereinafter “Villa Europa”).

1.  APPLICATION AND CLAIMS

Axel Brandenburg objects to the Court of Appeal issuing a declaration of enforcement of it
alleged arbitration. No amounts can be justified as reasonable in and of themselves.

Axel Brandenburg claims compensation for his legal costs in the Svea Court of Appeal with an amount
which will be specified later.

2.  BASICS
Axel Brandenburg and Villa Europa have not reached an arbitration agreement on April 24, 2020 alternatively
on June 26, 2020. There is no written agreement at all from April 24, 2020
alternatively on 26 June 2020. In the event that the Court of Appeal finds that the parties entered into an agreement with
the content that Villa Europa claims is the arbitration agreement with the application of both Swedish and Polish
quite invalid.

The Pan-European Court of Arbitration in Warsaw (“PESA”) is not a serious arbitration institution. Villa
Europe stands behind PESA and, according to Axel Brandenburg, the procedure is a part of one
elaborate fraud attempt. Recognizing and enforcing the purported arbitration is contrary to
public order.

Axel Brandenburg has not been given the opportunity to execute his claim.

The claim for legal costs put forward by Villa Europa is disputed in its entirety. No
amounts can be justified as reasonable in and of themselves.

3.  CIRCUMSTANCES

3.1. Background

Axel Brandenburg is a professor in astrophysics at the Nordic Institute for Theoretical Physics.

On April 8, 2020, Axel Brandenburg was contacted by someone claiming to be called Matteo
Ferensby and who in correspondence had a signature that showed he was active at
University of Warsaw. Matteo Ferensby asked if Axel Brandenburg wanted to participate in one
online debate (hereinafter "the Debate") regarding the spread of Covid-19 (appendix 1,
Email correspondence with Matteo Ferensby). Nowhere in the request document was it mentioned
anything about any fees or costs attributable to the Debate. Axel Brandenburg replied that
he was interested in participating in the Debate. If Axel Brandenburg hadn't been gone
the view that the University of Warsaw organized the Debate, he would not have participated in it
The debate.

Alex Brandenburg later came to participate in the Debate on April 24, 2020.

During May 2020, Axel Brandenburg was contacted by a person who called herself Anne
Adamchewsky who said he would handle the formalities in connection with the debate. She stated that
documents regarding copyright for publication of Axel Brandenburg's presentation had
sent to Axel Brandenburg by mail and he would sign the document and return them
to her (Appendix 2, Email correspondence with Anne Adamchewsky during May 2020). According to
Anne Adamchewsky needed the signatures to be able to publish the talk from the debate
on Youtube. Nowhere in the contacts with Anna Adamchewsky did any costs appear
connection to the Debate. Axel Brandenburg later signed what he perceived as one
approval of publication.

During August 2020, Anne Adamchewsky again contacted Axel Brandenburg and wrote that she
intended to forward a copy of the previously signed agreement to Axel Brandenburg's private
address. A few days later, Axel Brandenburg received another message from Anne
Adamchewsky where she stated that her cat had spilled coffee on the signed agreement
why a new agreement should be sent to Axel Brandenburg (appendix 3, E-mail correspondence
with Anne Adamchewsky during August 2020). In the email from Anne Adamchewsky
a completely different person "Dr Prasad" is indicated, which indicates that this was a mass mailing there different
recipients have been clipped into the same email template.

Axel Brandenburg does not have the original agreements that were sent to him. A letter
which Axel Brandenburg received in November 2021, however, contained two agreements that according to the agreements
must have been signed by Axel Brandenburg (appendix 4, letter from Villa Europa).

The one agreement must have been signed on May 13, 2020. The agreement is called "Video Lecturer
Agreement Letter”. In the general conditions of this agreement had a cost of 2,785 euros for
editing work entered in running text and in letters. Furthermore, disputes between the parties would
is tried arbitration in the form of "Sad Arbitrazowy przy Konfederacji Lewiatan w Warszaqie",
in English “Court of Arbitration at the Confederation of Lewiatan” or “Sad Arbitrazowy
Online in Wroclaw" in English "Court of Arbitration Online in Wroclaw". This is two
purported arbitration institutions other than the purported PESA arbitration institution such as Villa Europas
the application in the present case is based on.

Another agreement was also attached to the letter. This agreement must have been signed by Axel
Brandenburg on September 30, 2020. In this agreement, a cost of 790 euros had been entered
for participation in the seminar and 2,785 euros for editing work. Under this agreement, disputes would
is tried by a general court in Poland.

In connection with the receipt of the letter during November 2021 was the first time that Axel
Brandenburg registered the company name "Villa Europa".

Axel Brandenburg has subsequently not taken part in any documents from Villa Europa or them
alleged persons Matteo Ferensby and Anne Adamchewsky.

3.2. The parties have not entered into any written agreement on 24 April 2020 or 26 June
2020 which contains an arbitration clause

Villa Europa states that an agreement was entered into on 26 June 2020 (file attachment 1, page 3), and that a
agreement entered into on 24 April 2020 (file attachment 4). There is absolutely no written agreement
from those dates and certainly not an agreement that governs PESA's jurisdiction to hear a dispute
between the parties.

Of the agreements previously sent to Axel Brandenburg during November 2021 is general
court or other arbitration institute competent to hear disputes. However, these agreements are drawn up
after the Debate on 24 April 2020. In the event that there is an agreement from 24 April 2020 or
on June 26, 2020 with the content that Villa Europa claims Axel Brandenburg would have included
agreement regarding the same legal relationship which regulated that, on the one hand, three different arbitration institutes are
competent to hear disputes, partly that general courts in Poland are competent to hear disputes. IN
the context must also be emphasized that the various agreements allegedly include three different costs for
same thing i.e. participation in the Debate.

In accordance with Section 58 of the Arbitration Act (1999:116), Villa Europa has to demonstrate that a
arbitration agreement has been reached between the parties on 24 April 2020 or 26 June 2020 with the content
as Villa Europa claims.

3.3. PESA is not a serious arbitration institute

There is hardly any information to be found about PESA. The website available (www.pesa-
court.org) is extremely deficient and contains hardly any information (Appendix 5, extract from
PESA website).

When searching for who runs the website www.pesa-court.org, it appears that i
in fact, it is Villa Europa that operates the website www.pesa-court.org (Annex 6,
holder information to the PESA website). Furthermore, it appears that the website
was registered as late as September 28, 2021.

Villa Europa is a company that, according to its business description, conducts construction activities
(appendix 7, Villa Europa's business description).

At the address that PESA provides for its operations, there is no trace of PESA operating
no business and no person at the scene had heard of PESA (appendix 8, investigation
regarding PESA's address).

Villa Europa thus seems to have set up its own arbitration court where they try their own claims
claims against private individuals to then apply for enforcement based on an alleged arbitration award.
Villa Europa has therefore deemed itself competent to try the dispute. In this context
should also be emphasized that PESA seems to be trying to imitate the European Court of Arbitration (ESA) which
is a legitimate arbitral tribunal.

Villa Europa's procedure appears to be as follows:

1. A person called Matteo Ferensby attributes to researchers and asks if they want to participate in one
online debate. In the correspondence, an address to the University of Warsaw is given.
Nothing about costs is mentioned in the correspondence. Matteo Ferensby is not employed by
University of Warsaw (Annex 9, confirmation from the University of Warsaw).

2. After the online debate, prescriptive agreements are sent from Villa Europa which are titled as
approval of publication of material. In the text of the agreement, Villa Europa sneaks in high
costs linked to the debate and arbitration clauses to try disputes. In this
context it must be emphasized that the normal thing in debates of the present kind is that the
person speaking does not pay any fee and any costs for participation
are usually low.

3. Documents in Polish are sent to the researcher which the researcher usually does not understand. If not
response is received within a short period, PESA will notify an alleged arbitration award. As stated
is PESA not a serious arbitration institute but Villa Europa seems to be behind PESA.

4. Villa Europa attempts to demand payment from the researcher, either directly from the researcher or
by applying for enforcement.

Villa Europa has directed demands against private individuals in the majority of countries in Europe as far as it can
is described as an elaborate fraud attempt (Appendix 10, compilation of people who
subjected to Villa Europa).

Villa Europa and its representative Krzysztof Sienicki have previously tried to profile it
reputation of the American Chemical Society which was tested by an arbitral tribunal which found
that Villa Europa tried to gain commercial advantage by using the American
the chemist's association's trademark (Appendix 11, Arbitration at FORUM on 12 February 2018).

The alleged arbitration award in the present case appears to have been drawn up hastily and in a form of
mass handling. Among other things, the name of a completely different private person "Henrik Björn Hult" appears
as stated under point 2 of the translation of the decision (file attachment 4). Obviously someone has
person used a template and cut in names in order to be able to direct several parallel demands against different ones
people.

In another case at the Svea Court of Appeal, Villa Europa has applied for enforcement against another
private person in case Ö 4652-22. In both these cases it is the exact same alleged arbitrator who
has issued the respective arbitration award. Villa Europa itself states in its application that the alleged
the arbitration institute has randomly appointed arbitrators, which does not seem to be the case
(appendix 12, Injunction case Ö 4642-22).

3.4. An enforcement declaration would be contrary to ordre public

As a general rule, a foreign arbitration award based on an arbitration agreement is recognized and
enforced in Sweden according to Section 53 of the Arbitration Act (1999:116). From that main rule exists
the certain exceptions stated in §§ 54 and 55. It is said i.a. that a foreign arbitration does not
recognized and enforced, if the court finds that this would be manifestly inconsistent with
the foundations of the legal order in Sweden (55 § 2), i.e. such situations where a recognition or
an enforcement declaration would be contrary to ordre public. The provision corresponds to Article V
2. b) in the 1958 New York Convention on the Recognition and Enforcement of Foreign
arbitration awards.

The overall purpose of the provision is that courts and authorities should not participate
for enforcement in cases where it would be highly objectionable if this happened. It is mainly question
that elementary legal principles of a substantive or procedural nature have been set aside i
the arbitration or that the dispute is of a nature with which the courts do not deal. (See prop.
1998/99:35 p. 234, cf. NJA 2002 C 62.).

As shown in point 3.3, PESA is not a serious arbitration institute but seems to have been created
by Villa Europa. Axel Brandenburg is of the firm opinion that Villa Europa's
procedure constitutes an elaborate fraud attempt directed at private individuals who are researchers all around
in Europe.

In light of the above, the document invoked by Villa Europa should not
considered to constitute an arbitration award at all.

In the event that the Court of Appeal finds that the cited document constitutes an arbitration award, one
recognizing the alleged arbitration to be manifestly inconsistent with the grounds of
the legal system in Sweden.

3.5. Axel Brandenburg has not been given the opportunity to present his case

Axel Brandenburg has after he received the letter from Villa Europa in November
2021 established that it is an attempted fraud. Axel Brandenburg therefore has not
acknowledged some documents sent to him by Villa Europa and have therefore not been served either
the documents alleged to have been transmitted to him.

For the reasons in the translated purported arbitration, further are the circumstances regarding Axel
Brandenburg's opportunity to take part in the documents is very vaguely worded. It should according to it
alleged arbitration to have sent an invitation to Axel Brandenburg to submit
response on 20 June 2022, at the same time the response deadline must have expired on 17 June 2022, which appears
as strange.

In light of the above, Axel Brandenburg has had no opportunity to perform his
action in respect of Villa Europa's alleged claims.

3.6. Villa Europa's claimed legal costs are not reasonable

Villa Europa has, of course, requested compensation for legal costs amounting to
5,400 euros. The legal costs are not specified in more detail but are only stated as
attorney's fees. It appears from Villa Europa's application that Villa Europa has no representative in
the dispute but is represented by the managing director of the company.

In light of what has emerged about Villa Europa's actions, no part of it can
the submitted claim for legal costs is justified as reasonable in and of itself.

3.7. Something about the Court of Appeal's review

The rules on the enforcement of foreign arbitration awards in the Law (1999:116) on arbitration
certainly means a limited review for the Court of Appeal. However, courts and authorities must
not participate in enforcement in cases where it would be highly objectionable if this happened.

In the present case, it is clear to Axel Brandenburg that the alleged arbitration constitutes one
victim of an attempted fraud by Villa Europa. The circumstances surrounding the Debate and the many
different versions of the same agreement that have emerged are remarkable. The same applies to them
various costs sneaked into the agreements and the design of the purported arbitration award.
Taken together, the circumstances raise questions about the purpose of the proceedings and the parties
underlying transactions.

If there is considerable doubt as to whether enforcement is contrary to ordre public should
it is incumbent on Villa Europa to show reasonable explanations for the current conditions (see Svea
Court of Appeal's decision in case Ö 7419-15). If Villa Europa does not succeed in this, the Svea Court of Appeal must refuse
application based on the provision on ordre public.

4.  EVIDENCE

Axel Brandenburg tentatively invokes the following evidence.

4.1. Written evidence

4.1.1.  E-mail correspondence with Matteo Ferensby (appendix 1), for verification of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020.

4.1.2.  Email correspondence with Anne Adamchewsky during May 2020 (Appendix 2), to
strengthening of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020.

4.1.3.  E-mail correspondence with Anne Adamchewsky (Appendix 3), in support of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020

4.1.4.  Letter from Villa Europa (Appendix 4), in support of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020

4.1.5.  Extract from the PESA website (Appendix 5), in support of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020

4.1.6.  Information about holders to PESA's website (Appendix 6), for proof of
that Villa Europa owns the domain for the website www.pesa-court.org,
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020

4.1.7.  Villa Europa's business description (appendix 7), in support of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020

4.1.8.  Investigation regarding PESA address (appendix 8), for verification of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020

4.1.9.  Confirmation from the University of Warsaw (Appendix 9), in support of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020

4.1.10. Compilation of persons exposed to Villa Europa (appendix 10), to
strengthening of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020

4.1.11. Arbitration at FORUM on February 12, 2018 (Appendix 11), in support of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020

4.1.12. Injunctive case Ö 4652-22 (appendix 11), in support of
that Villa Europa's application constitutes a part of fraudulent activity, and
that PESA is not a serious arbitration institution,

and in refutation of
that Axel Brandenburg entered into an agreement containing an arbitration clause on 24 July 2020

Stockholm day as above
Thomas Ekenberg
Lawyer
Michael Erici
Assistant lawyer

Appendices.
1. Email correspondence with Matteo Ferensby
2. Email correspondence with Anne Adamchewsky during May 2020
3. Email correspondence with Anne Adamchewsky
4. Letter from Villa Europa
5. Extract from the PESA website
6. Information about holders to the PESA website
7. Villa Europa's business description
8. Investigation regarding PESA address
9. Confirmation from the University of Warsaw
10. Compilation of persons exposed to Villa Europa
11. Arbitration at FORUM on February 12, 2018
12. Injunctive case Ö 4652-22