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This document is the Claimant's Statement of Costs, submitted in the PCA-administered arbitration against the Plurinational State of Bolivia. The submission formally requests that the Arbitral Tribunal order the Respondent to bear the entirety of the costs incurred by the Claimant throughout the proceedings.
The Claimant seeks reimbursement for several categories of expenses, including: (i) advances paid for the fees of the Tribunal and the administrative costs of the Permanent Court of Arbitration; (ii) fees and costs for legal representation and independent experts; and (iii) travel and other expenses for party representatives. The costs claimed cover all major phases of the arbitration, from the initial Statement of Claim through the Merits Hearing (Paris, May 2019) and the virtual Quantum Hearing (March-April 2021). The submission also specifies that costs were incurred in relation to ancillary proceedings, notably a discovery application under Section 1782 of the United States Code in a U.S. District Court.
The document provides a summary of costs, identifying amounts billed by its legal counsel, Freshfields Bruckhaus Deringer US LLP and Ferrere, and its experts, including Compass Lexecon and SRL Consulting (formerly Roscoe Postle Associates Inc). The submission is supported by an affidavit from counsel, Ms. Noiana Marigo, certifying the fees and disbursements.