Contract analysis

1. Introduction and Identification of Counsel We write jointly on behalf of the Claimant and the Respondent in the above-referenced proceedings to submit a joint request for the suspension of proceedings, as further described below. Calderwood & Harkness LLP writes on behalf of the Claimant, Dunmore Energy Holdings Ltd. ("DEH" or the "Claimant"), an exempted company duly incorporated and existing under the laws of th

2. Procedural Background On March 15, 2022, DEH filed a Request for Arbitration with the International Centre for Settlement of Investment Disputes ("ICSID" or the "Centre") pursuant to Article 36 of the Convention on the Settlement of Investment Disputes between States and Nationals of Other States (the "ICSID Convention"), asserting claims against the Republic of Valderia arising from the expropriation of DEH's inv

3. State-to-State Diplomatic Consultations The Parties wish to inform the Secretary-General that, following the filing of the Request for Arbitration, the Government of the United Kingdom of Great Britain and Northern Ireland, acting through the Foreign, Commonwealth & Development Office ("FCDO"), and the Government of the Republic of Valderia, acting through the Ministry of Foreign Affairs (under the direction of Am

4. Joint Request for Suspension In light of the foregoing circumstances, and pursuant to ICSID Arbitration Rule 10(2), or, to the extent that this provision may be held to apply only after the constitution of the Tribunal, under the inherent powers of the Secretary-General to administer proceedings during the pre-constitution phase of a case, the Claimant and the Respondent hereby jointly and respectfully request tha

5. Reservation of Rights Each Party expressly and unequivocally reserves all of its rights, claims, defenses, and arguments under the ICSID Convention, the ICSID Arbitration Rules, the UK-Valderia BIT, general international law, and any other applicable law or instrument. Nothing in this joint request, the fact of the suspension of proceedings, or any communications between the Parties in connection therewith shall c

6. Constitution of the Tribunal Given the nature and purpose of this joint request for suspension, the Parties respectfully suggest that the process for the constitution of the Tribunal — including, without limitation, the nomination by the Respondent of its party-appointed arbitrator and the appointment of the presiding arbitrator by agreement of the Parties or, failing such agreement, by the Chairman of the ICSID A

7. Correspondence and Notices The Parties request that all correspondence, notifications, and other communications from the Centre in connection with ICSID Case No. ARB/22/11 continue to be directed to the following representatives: For the Claimant: Vivienne St. Claire Partner Calderwood & Harkness LLP 55 Bishopsgate London EC2N 3AH United Kingdom With copies to: Dr. Gabriel Castaño Herrera Castaño Herrera & Asociad

8. Closing The Parties respectfully request that the Secretary-General confirm receipt of this joint request and the suspension of proceedings in ICSID Case No. ARB/22/11 at her or his earliest convenience. The Parties further request that any written acknowledgement or order issued by the Centre in connection with this request be communicated to both Parties simultaneously through the contact details set forth in Se