Contract analysis

1. Introduction The undersigned counsel write jointly on behalf of the Claimant, Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted company with its principal administrative offices in London, and the Respondent, the Republic of Valderia, respectively. Calderwood & Harkness LLP acts as lead international counsel for DEH, and Harcastle Fenton LLP acts as lead international counsel for the Republic of Vald

2. Procedural History of Suspension Requests By way of background, the parties wish to place on record the procedural history of the suspension of proceedings in this case, so as to provide the Secretary-General and the ICSID Secretariat with a complete and consolidated account of the prior joint requests and the corresponding confirmations received. On June 17, 2022, approximately two months following registration o

3. Basis for Continued Suspension — Ongoing Diplomatic Consultations The parties confirm that the state-to-state diplomatic consultations that formed the basis for the original request for suspension, and for each subsequent renewal thereof, remain ongoing as of the date of this letter. Specifically, consultations between the United Kingdom Foreign, Commonwealth & Development Office ("FCDO") and the Ministry of Forei

4. Status of Tribunal Constitution The parties wish to confirm that the Tribunal in ICSID Case No. ARB/22/11 has not yet been constituted. At the time the proceedings were suspended in June 2022, the constitution of the Tribunal was at an early stage. Specifically: (a) The Claimant had nominated Professor Ingrid Svensson, a Swedish national and Professor of International Investment Law at the University of Uppsala, a

5. Joint Consent and Reservation of Rights Both parties hereby confirm their joint and mutual consent to the continuation of the suspension of proceedings in ICSID Case No. ARB/22/11. This consent is freely given and reflects the considered judgment of each party, in consultation with its respective counsel, that the continued suspension is in the best interests of both parties and of the efficient administration of

6. Proposed Next Review Date The parties jointly propose that the next review date for the suspension of proceedings be set for December 12, 2024, which is approximately six months from the date of this letter and consistent with the approximately six-month review intervals that have been observed in each of the prior renewal cycles. The parties undertake that, at or before the proposed next review date of December 1

7. Request for Confirmation In light of the foregoing, the parties respectfully request that the Secretary-General confirm receipt of this joint letter and the continuation of the suspension of proceedings in ICSID Case No. ARB/22/11 through the proposed next review date of December 12, 2024, or such other date as the Secretary-General may consider appropriate. The parties remain available at the Secretary-General's

8. Closing The parties wish to express their sincere respect and gratitude to the Secretary-General and to the staff of the ICSID Secretariat for their continued patience, professionalism, and accommodation in connection with the administration of this matter. The parties are mindful of the administrative burden that repeated suspension requests may place upon the Secretariat, and they appreciate the Centre's facilit