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ANNEX A

AMENDED PROCEDURAL TIMETABLE

EVENT Date
(The Respondent has the right to make focused requests for documents to the Claimants relating to the three jurisdiction/admissibility issues that it has identified in paragraph 22 of its letter of 19 June 2020 as soon as practicable. The Claimant will endeavour to comply with those requests as soon as possible. The Tribunal will promptly rule on any disputed issues.) Immediately
Joinder Application from a Third Party (to join as a claimant) 9 July 2020
Parties’ Observations on the Joinder Application. 8 August 2020
Reply of the Joinder Party to the Parties’ Observations 8 September 2020
Tribunal’s Decision on the Joinder Application 8 October 2020
Claimants’ Memorial on the Merits 10 December 2020
Respondent’s Request for Bifurcation (if any) 8 January 2021
Claimants’ Reply to Request for Bifurcation 21 January 2021
Tribunal’s Ruling on Bifurcation 1 February 2021
If bifurcation
Respondent’s Memorial on Preliminary Objections 26 February 2021
Claimants’ Counter-Memorial on Preliminary Objections 26 March 2021
Respondent’s Reply on Preliminary Objections 9 April 2021
Claimants’ Rejoinder on Preliminary Objections 25 April 2021
Hearing on Jurisdiction¹ 18-19 May 2021
If no bifurcation
Respondent’s Counter Memorial on the Merits 16 April 2021

¹ If jurisdiction/admissibility is upheld in whole or in part, the Tribunal will then fix a timetable for the next phase of the procedure.

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Requests for Production of Documents 14 May 2021
Responses and Objections to Requests for Production of Documents (including submissions on what would be an acceptable scope for any relevant document requests²) 11 June 2021
Replies to Responses and Objections to Requests for Production of Documents & Production of Documents in respect of which there are no Objections 16 July 2021
Tribunal’s Rulings on Objections to Requests for Production of Documents 2 August 2021
Parties’ Production of Documents Ordered by Tribunal 6 September 2021
Claimants’ Reply Memorial on the Merits 5 December 2021
Respondent’s Rejoinder Memorial on the Merits 4 March 2022
Pre-hearing conference April 2022
Hearing Week of 6 June 2022

² E.g. if a party objects to a request as being overly broad, then it is invited, where reasonable, to propose a formulation of the request that it would consider to be acceptable.