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IN THE MATTER OF AN ARBITRATION

BEFORE A TRIBUNAL CONSTITUTED IN ACCORDANCE WITH

THE FREE TRADE AGREEMENT BETWEEN THE REPUBLIC OF KOREA AND THE

UNITED STATES OF AMERICA, DATED 30 JUNE 2007

- and -

THE ARBITRATION RULES OF THE UNITED NATIONS COMMISSION

ON INTERNATIONAL TRADE LAW, 2013

PCA CASE NO. 2018-51

-between-

ELLIOTT ASSOCIATES, L.P. (U.S.A.)

(the “Claimant”)

-and-

REPUBLIC OF KOREA

(the “Respondent,” and together with the Claimant, the “Parties”)


PROCEDURAL ORDER NO. 5


The Arbitral Tribunal

Dr. Veijo Heiskanen (Presiding Arbitrator)

Mr. Oscar M. Garibaldi

Mr. J. Christopher Thomas QC

Registry

Permanent Court of Arbitration

26 August 2019

PCA 285442

[Page 2]

I. PROCEEDINGS

1. On 14 May 2019, the Tribunal issued Procedural Order No. 2, determining the procedural timetable for the present arbitration. Procedural Order No. 2 contemplated four alternative tracks for the proceedings, depending on whether the Respondent chose to raise any objections to jurisdiction or admissibility, the basis of such objections, and whether such objections would be dealt with in a preliminary phase of the proceedings.

2. On 22 August 2019, the Respondent, with the agreement of the Claimant, requested the Tribunal’s approval of an extension of time for the submission of its Statement of Defence, from 30 August 2019 to 27 September 2019, as well as a number of related amendments to the procedural timetable.

3. By the same letter, the Respondent confirmed that, without prejudice to any jurisdictional or other objections it might raise in its Statement of Defence, it would not seek bifurcation of the present proceedings.

II. THE TRIBUNAL’S DECISION

4. In view of the above, the Tribunal decides as follows:

(a) The Tribunal takes note of, and approves, the revised procedural timetable as agreed by the Parties;

(b) The Tribunal further takes note of the Respondent’s confirmation that it will not seek bifurcation of the proceedings, while reserving its right to raise jurisdictional and other objections; and

(c) The proceedings shall be conducted in accordance with the revised timetable reproduced in the Annex to the present Procedural Order.

Place of Arbitration: London, United Kingdom

Signature

Dr. Veijo Heiskanen

(Presiding Arbitrator)

On behalf of the Tribunal

PCA 285442

[Page 3]

Annex

Phase 1: First-Round Written Submissions
Amended Statement of Claim
Statement of Defence (and any preliminary objections)
Phase 2: Document Production and Non-disputing Party Submission
Document production requests
Objections to production
Responses to objections (submitted to Tribunal)
Voluntary production
Notice by non-disputing Party that it intends to file a submission in accordance with Article 11.20(4) of the Treaty
Tribunal decision on objections
Involuntary production and completion of voluntary production
Non-disputing party submission in accordance with Article 11.20(4) of the Treaty
Phase 3: Second-Round Written Submissions
Statement of Reply (and Defence to Preliminary Objections, if any)
Statement of Rejoinder (and Reply to Preliminary Objections, if any)
Claimant’s Rejoinder on Preliminary Objections, if any)
Phase 4: Hearing
Notification of witnesses and experts to be cross-examined
Pre-Hearing Conference
Hearing
Claimant
4 April 2019
Respondent
27 September 2019
Parties
1 November 2019
Parties
22 November 2019
Parties
13 December 2019
Parties
6 January 2020
United States
6 January 2020
Tribunal
10 January 2019
Parties
7 February 2020
United States
7 February 2020
Claimant
7 June 2020
Respondent
7 September 2020
Claimant)
29 October 2020)
Parties
23 November 2020
All
7 December 2020
All
The weeks of 25 January and 1 February 2021

PCA 285442