Procedural Context and Purpose

This document comprises correspondence dated 8 July 2026 from counsel for JSC State Savings Bank of Ukraine (Oschadbank) to counsel for the Russian Federation, filed as Exhibit B in related United States proceedings. The letter addresses the Russian Federation's request for a further stay of the English enforcement proceedings (Claim No. CL-2023-000502) pending the resolution of its appeal in cassation before the French courts regarding the underlying arbitral award dated 26 November 2018.

Parties' Positions on the Stay of Proceedings

Counsel for the Claimant characterizes the Respondent's cassation appeal against the 1 July 2025 judgment of the Paris Court of Appeal as a dilatory tactic devoid of legal merit. Nevertheless, to preserve judicial economy and minimize costs, the Claimant consents in principle to a limited stay of the English proceedings until the French Cour de cassation renders its judgment. Crucially, the Claimant rejects the Respondent's attempt to predicate the stay on a prospective revision application before the arbitral tribunal, noting that no such application is currently pending following the Paris Court of Appeal's decisions of 23 June 2026.

Reservations and Proposed Order

The Claimant expressly reserves all rights regarding the legal effects of the 23 June 2026 Paris Court of Appeal decisions, including whether they afford the Respondent any legitimate basis to initiate new revision proceedings. The letter concludes by enclosing an amended draft Consent Order reflecting the Claimant's conditional agreement to the stay, strictly limited to the pending cassation appeal, while rejecting the broader terms proposed by the Respondent.