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INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES




The Lopez-Goyne Family Trust and others

v.

Republic of Nicaragua

(ICSID Case No. ARB/17/44)



PROCEDURAL ORDER NO. 3



Members of the Tribunal
Prof. Luca G. Radicati di Brozolo, President of the Tribunal
Mr. José A. Martínez de Hoz, Arbitrator
Prof. Brigitte Stern, Arbitrator

Assistant to the President of the Tribunal
Mr. Gregorio Baldoli

Secretary of the Tribunal
Ms. Catherine Kettlewell





22 October 2021
(Amended on 28 October 2021)

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I. PROCEDURAL BACKGROUND

1. On 21 July 2021, the Tribunal invited the Parties to consult amongst themselves regarding the plans for the hearing and share their views in light of the ongoing pandemic restrictions on traveling. On 4 August 2021, the Parties submitted their views indicating that while both Parties agreed to an in-person hearing, they disagreed on the alternatives if traveling restrictions remained for the week of the scheduled hearing.

2. On 6 August 2021, the Tribunal informed the Parties that it agreed that efforts should be made to hold an in-person hearing and decided that if it was impossible, the Parties should be ready to hold the hearing in remote format in the scheduled dates. The Tribunal further noted that remote hearings “have become the routine way to carry litigation and arbitration, including in ICSID cases, when in-person hearings are impossible due to travel and sanitary restrictions.” In that same communication, the Tribunal invited the Parties to prepare for arrangements in case of a remote hearing.

3. On 28 September 2021, the Tribunal notified the Parties that sanitary and travel restrictions were still in place in several locations which would make an in-person hearing challenging. The Tribunal also noted that it would be amenable to a postponement if both Parties agreed to such postponement. To this date, the Parties have not informed the Tribunal of such agreement.

4. Pursuant to Section 22 of Procedural Order No. 1 (as amended), a pre-hearing organizational meeting between the Parties and the Tribunal was held by telephone conference on 15 October 2021 (the “Pre-Hearing Conference”), to discuss any outstanding procedural, administrative, and logistical matters in preparation for the Hearing. Participating were:

Tribunal:
Prof. Luca Radicati di Brozolo

Assistant to the President of the Tribunal:
Mr. Gregorio Baldoli

ICSID Secretariat:
Ms. Catherine Kettlewell, Secretary of the Tribunal

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On behalf of the Claimants:
Mr. Jean Paul Dechamps
Mr. Gustavo Topalian
Dr. Tariq Baloch
Mr. Marcos G. A. Sassot

On behalf of the Respondent:
Mr. Paul S. Reichler
Ms. Tafadzwa Pasipanodya
Ms. Christina Beharry
Ms. Elisa Méndez Bräutigam

5. During the Pre-Hearing Conference, the Parties and the Tribunal discussed the draft Procedural Order circulated to the Parties on 5 October 2021, and the Parties’ joint statement of 12 October 2021 indicating to the Tribunal the agreements reached on the various items, as well as their respective positions where no agreement was reached.

6. An audio recording of the Pre-Hearing Conference was made and deposited in the archives of ICSID, and it was made available to the Members of the Tribunal and the Parties on 15 October 2021.

7. The Tribunal has considered the Parties’ positions and, in the present Order, sets out the procedural rules that the Parties have agreed upon and/or the Tribunal has determined will govern the conduct of the Hearing.

II. ORGANIZATION OF THE HEARING

A. DATE AND FORMAT

8. The Hearing will take place virtually through the video conference platform, Zoom, hosted by Sparq on 15 November to 20 November 2021. The details to join the Zoom session will be shared by the ICSID Secretariat in advance of the Hearing.

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B. ORDER OF PROCEEDINGS AND SCHEDULE

9. The hearing’s schedule will be as follows (which will include a 30 minute buffer at the end of Days 1 through 5 and which shall not be included in the total sitting time):

10. The order of the timetable is reflected in the agenda attached as Annex A.

11. There will be at least one break during each Hearing day, except for Day 6, of 1 hour and two breaks of 15 minutes each. Additional short breaks may be taken as reasonably requested by any participant.

12. The Tribunal reserves discretion to adjust the Hearing schedule as needed to accomplish the prescribed agenda and to accommodate any technical disruptions. In principle, witnesses and experts should be available one-half day before and after the time they are scheduled to be examined.

C. TIME ALLOCATION

13. After hearing the Parties’ arguments during the pre-hearing organizational meeting, the Tribunal decided that, in light of the number of witnesses and experts presented by each Party, the Claimants will be allocated 60 percent of the working time available to the Parties and Respondent will be allocated 40 percent of such time. The Tribunal also decided to extend the Hearing one more day (20 November 2021) for the Parties to make their closing statements (up to 90 minutes from each Party).

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14. Accordingly, considering the total number of Hearing days (six days),¹ the Claimants shall have a total of 16 working hours and the Respondent shall have 10.5 working hours available during the entire Hearing.

15. The Tribunal will reserve 1.5 hours for housekeeping, administrative issues and questions to the Parties not accounted for in paragraph 17 below.

16. For purposes of organization of the Hearing, the Parties shall have the following allocated time for each stage of the Hearing:

(a) Opening Statement. Each Party shall be allowed a maximum of 3 hours for its Opening Statement.

(b) Witnesses/Expert cross-examinations:

o Direct Examination of Fact Witnesses. The direct examination of a fact witness envisioned by Section 21.6.2 of Procedural Order No. 1 (as amended) shall not exceed 15 minutes.

o Direct Presentations by Experts. The presentation by an expert envisioned in Section 21.6.3 of Procedural Order No. 1 (as amended) shall not exceed 45 minutes.

(c) Closing statements: Each Party shall be allowed a maximum of 1.5 hours for its Closing Statement.

17. In calculating time used during the Hearing, the Tribunal will consider the following principles:

(a) Time used by the Parties in oral argument shall be attributable to the Party making such argument.


¹ Considering Hearing Days 1 through 5 with a total of 5 hours (excluding breaks) and Day 6 with a total of 3 hours (excluding breaks), and that the Tribunal will reserve 1.5 hours, the total working hours for the Hearing is 26.5 working hours which will be distributed between the Parties in the percentage decided by the Tribunal.

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(b) Time attributable to minor Tribunal questions to counsel, to clarify points being made, shall not interrupt the clock for the Party otherwise conducting that argument, but any extended Tribunal questioning (beyond five minutes) will be allocated to reserved Tribunal time.

(c) Time spent on incidental procedural discussions will not be allocated to Party time, but in the event of significant applications or objections requiring extended discussion, time spent resolving the matter will be charged against the Party which unsuccessfully made the application or objection, or wrongfully resisted it.

(d) Lost time attributed to the late arrival of counsel, other than for technological reasons outside of reasonable Party control, will be charged against the Party responsible.

(e) The Parties are expected to seek to use the Hearing days efficiently and to avoid unnecessary slippage. In the event of excess slippage, the Tribunal may revisit the length of one or more sitting days, or in unusual circumstances the time allocations of the Parties, bearing in mind principles of predictability, equal treatment and a fair opportunity for the Parties to be heard.

18. As agreed by the Parties in Section 23.5 of Procedural Order No. 1 (as amended), time will be accounted for in accordance with the chess clock method. The Secretary of the Tribunal will keep a chess clock account of time used and advise the Parties at the end of each Hearing day of the length of time used and time remaining.

D. DOCUMENTS FOR USE AT THE HEARING

1. Electronic Hearing Bundle

19. There shall be a single Electronic Hearing Bundle (PC and Mac compatible), to be prepared jointly by the Parties. The Electronic Hearing Bundle shall contain all pleadings, witness statements, expert reports, exhibits, legal authorities and Tribunal orders or decisions on file to date, with a consolidated hyperlinked index. It shall not contain any document not previously filed.

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20. The Parties shall indicate by 8 November 2021 whether any material is to be considered protected information pursuant to Article 10.21.2 of CAFTA-DR. If such protected information will be used during the Hearing, the Parties shall make a proposal as to the appropriate arrangements to protect the information from disclosure by 12 November 2021.

21. The Electronic Hearing Bundle shall be uploaded by the Parties to a designated sub-folder in the BOX filesharing platform no later than 8 November 2021. To ensure proper operation of the hyperlinked index, the entire Electronic Hearing Bundle shall be housed within one folder and then uploaded to BOX as a single zip file. Should the size of the zip file make the upload to BOX impossible, the Parties shall upload the organized Electronic Hearing Bundle to a designated sub-folder on to the BOX filesharing platform and including a consolidated (non-hyperlinked) index.

22. Prior to the Hearing, the Members of the Tribunal, the Assistant of the President of the Tribunal, the Secretary of the Tribunal and the Parties shall download the Electronic Hearing Bundle from BOX into their own devices to have access to it offline during the Hearing. The court reporters and interpreters will also be provided a copy of the Electronic Hearing Bundle via the ICSID Secretariat.

2. Demonstrative Exhibits

23. Demonstrative exhibits (including a Power Point or other slide presentations) shall be used in accordance with Section 18.8 of Procedural Order No. 1 (as amended) (reproduced below), with certain adjustments indicated in paragraph 24 below:

18.8. Demonstrative exhibits (meaning representations such as diagrams, charts, graphs, models and computer simulations that depict and explain evidence otherwise submitted) may be used at any hearing, provided they contain no new evidence. Each party shall number its demonstrative exhibits consecutively, and indicate on each demonstrative exhibit the number of the document(s) from which it is derived. The party submitting such exhibits shall provide them in electronic and hard copy to the other party, the Tribunal Members, the Tribunal Secretary, the court reporter(s) and interpreter(s) at the hearing at a time to be decided at the pre-hearing organizational meeting.

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24. To account for the virtual/remote nature of the Hearing, Section 18.8 of Procedural Order No. 1 (as amended) above is amended such that: (i) a hard copy submission of demonstrative exhibits is not required; and (ii) an electronic copy of each demonstrative exhibit shall be distributed by the Party intending to use it via email sent to the entire case email distribution for each Party, the Secretary of the Tribunal, the Members of the Tribunal, and to the Assistant to the President of the Tribunal, no later than one hour prior to its use, in order to facilitate offline access to the demonstrative exhibit by the Hearing participants. This will enable participants to print the demonstrative exhibit if desired.

25. In addition, promptly after the conclusion of the Hearing day in which the corresponding demonstrative exhibit is used, the Parties shall upload such demonstrative exhibit to the case folder in the BOX filesharing platform, designating each with the corresponding number: “CD-” for Claimants’ demonstrative exhibits, and “RD- ” for Respondent’s demonstrative exhibits.

3. Electronic Presentation of Evidence

26. Hearing participants are advised to have the Electronic Hearing Bundle and any demonstrative exhibit previously distributed in accordance with paragraph 24 above downloaded into their own devices and available for access offline.

27. Any Hearing Participant has the technical ability to display a document to all Hearing Participants using Zoom’s “Share Screen” function. The Participant displaying the document will be the only one with the ability to scroll through the document being displayed.

28. Documents that do not form part of the record may not be displayed at the Hearing.

E. AUDIO/VIDEO RECORDING

29. The provisions of Procedural Order No. 1 (as amended), Section 24.1 concerning audio recording (reproduced below) apply.

24.1. Sound recordings shall be made of all hearings and sessions. The sound recordings shall be provided to the parties and the Tribunal Members.

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30. The audio and video recording shall be made by the ICSID Secretariat, and it will be shared with the Parties and the Members of the Tribunal at the conclusion of the Hearing. Hearing Participants shall not otherwise record, via audio, video or screenshot the Hearing or any part of it.

F. TRANSCRIPTION

31. The provisions of Procedural Order No. 1 (as amended), Sections 12.8, 12.9, 24.2, and 24.3 concerning transcription (reproduced below) apply, with the adjustments indicated in paragraphs 32 and 33 below.

12.8. The testimony of a witness called for examination during the hearing who prefers to give evidence in either procedural language shall be interpreted simultaneously into the other procedural language. Witness and expert testimony in a language other than English or Spanish shall be interpreted into the procedural languages as required.

12.9. The parties will notify the Tribunal, as soon as possible, and no later than at the pre-hearing organizational meeting (see §22 below), which witnesses or experts require interpretation.

[...]

24.2. Verbatim transcript(s) in the procedural language(s) shall be made of any hearing and session other than sessions on procedural issues. Unless otherwise agreed by the parties or ordered by the Tribunal, the verbatim transcripts shall be available in real-time using LiveNote or similar software and electronic transcripts shall be provided to the parties and the Tribunal on a same-day basis.

24.3 The parties shall agree on any corrections to the transcripts within 45 days of the later of the dates of the receipt of the sound recordings and transcripts. The parties will correct only the original language version of the transcripts (e.g. only the Spanish transcript of Spanish language testimony). The original language version of the transcript will be the only authoritative transcript for use in any post-hearing brief or other subsequent pleading or presentation. The agreed corrections may be entered by the parties in the transcripts (“revised transcripts”). The Tribunal shall decide upon any disagreement between the parties and any correction adopted by the Tribunal shall be entered by the parties in the revised transcripts.

32. Real-time court reporting in English and Spanish shall be made available to the Hearing Participants via an online link connection to be provided by the English and the Spanish court reporters. Hearing Participants shall connect to the transcript by opening this link in

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a browser window separate from the Zoom browser window. The details (link, password) and instructions to connect to the streamed transcripts shall be provided by the ICSID Secretariat to the Hearing Participants before the start of the first Hearing day.

33. The deadline for corrections to the transcript shall be 45 days following the later of the dates of the receipt of the sound recordings and/or transcripts.

G. INTERPRETATION

34. ICSID will make the required arrangements for simultaneous interpretation into English and Spanish and communicate them to the Parties and Tribunal in due course.

35. Each Participant should select a language channel when connecting to the Hearing (English or Spanish). Once a language selection is made, it is highly recommended that the Participant only use that language and avoid switching interpretation channels.

36. The Participants should speak slowly, one person at a time, and should pause briefly when handing the floor to another Participant.

37. Each Active Participant should, insofar as possible, circulate any speaking notes to the interpreters prior to the start of each intervention. These notes should be emailed directly to the interpreters (see Annex B with their email addresses) and are to be treated as confidential information.

H. EXAMINATION OF WITNESSES AND EXPERTS

38. The examination of witnesses and experts shall be carried out in accordance with Section 21 of Procedural Order No. 1 (as amended). In light of the virtual modality of the Hearing, the Parties have also agreed that this section H will further apply to the examination of witnesses and experts.

39. During the pre-hearing organizational meeting, the Parties agreed to the following:

a. A fact witness shall not be present in the Hearing room during the hearing of oral testimony, discuss the testimony of any other witness who has already testified prior

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to giving his/her testimony, or read any transcript of any oral testimony, prior to his or her examination. This condition does not apply to experts.

b. If a witness or expert’s examination is interrupted and must continue on the following hearing day, the witness or expert may not speak or contact any of the Parties, their representatives, counsel or other witnesses and experts (or their assistants) until the examination is completed. The Parties shall use their best efforts to ensure that the examination of a given witness or expert is conducted in its entirety on the same day.

40. Each Party shall have the right to have a representative present at the location where any witness or expert is being examined by the other Party. To this effect, each Party shall inform the other Party the precise address from where the witness or expert will be giving evidence at least 72 hours before such examination is scheduled to take place. The opposing party representative present at the location from where the witness or expert is being examined will not be allowed to cross-examine the witness. Direct, cross and redirect examination shall be conducted virtually.

41. Each Party shall be responsible for ensuring that full copies of the documents they intend to use during the direct examination of their witnesses/experts and the cross-examination of the opposing Party’s witnesses/experts are accessible to the respective witness and expert during the examination. The parties may elect to provide physical binders of documents for cross-examination of the opposing party’s witnesses and experts.

42. Each Party shall make sure that the witnesses and experts it presented have access to the electronic devices necessary for their examination, such as a computer (preferably with two screens) and headphones.

43. Witnesses shall avoid sitting with a window or source of light behind them. The Tribunal may, at any time during the examination of a witness, direct the witness to show on camera the room where the examination is being held.

44. In cases where two or more experts are identified as authors of an expert report, one of them shall be designated as main expert by the Party appointing him or her by 8 November

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2021. On the same date, each Party will indicate the issues or sections for which each expert is responsible. The main expert shall be entitled to refer any questions posed by a Party – whether in full or in part– to any of the other experts. Only one expert shall respond to a given question during examination.

I. POST-HEARING SUBMISSIONS AND STATEMENTS OF COSTS

45. The provisions of Procedural Order No. 1 (as amended), Sections 25.1 and 25.2 (reproduced below) apply.

23.1. The Tribunal, in consultation with the parties, shall decide whether or not to order post-hearing briefs at an organizational meeting prior to the oral hearing or during the course of the oral hearing.

23.2. In accordance with Arbitration Rule 28(2), promptly after the closure of the proceeding, each party shall submit to the Secretary of the Tribunal a statement of costs reasonably incurred or borne by it in the proceeding.

J. OPEN HEARING

46. Pursuant to CAFTA-DR Article 10.21.2, hearings shall be open to the public. Due to the modality of the Hearing and in order to comply with the requirements of Section 23.6 of Procedural Order No. 1 (as amended) and CAFTA-DR Article 10.21.2, the Hearing will be recorded and posted on ICSID’s website for public access. The recording will be posted on the ICSID website within 30 days after the conclusion of the Hearing and will be available for 30 days.

47. Any information designated by one or both of the Parties as being protected will be excluded from the recordings. The required mechanics for the Parties to alert the Tribunal about the use of protected information during the Hearing will be agreed by the Parties and informed to the Tribunal by 12 November 2021.

48. The availability of the Hearing recordings will be announced publicly via the ICSID website in English and Spanish.

K. VIRTUAL HEARING ARRANGEMENTS

49. The following procedures shall be followed in order to ensure the good conduct of the virtual hearing:

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1. Testing

50. The ICSID Secretariat and/or Sparq will conduct technical tests with the Tribunal and each Party in advance of the Hearing, to test connectivity to the video conference platform Zoom and to the real-time transcription. ICSID recommends a minimum of one test for each site that will connect to the Hearing, and for as many Hearing Participants as possible to connect for each test. The date of each test and the access details will be communicated in due course.

2. Participants

51. Each Party has provided its List of Participants (“Hearing List of Participants”) for the Hearing, using the format provided in Annex B by 12 October 2021. In addition, each Party has designated the participants that will have an active speaking role (“Active Participants”), to distinguish them from those who will be passive attendees (“Passive Participants”).

52. All Hearing Participants shall clearly denote their names and affiliation when connecting to Zoom. Example: “[ICSID] Jane Doe.” Any name appearing in Zoom shall also be listed on the Hearing List of Participants (see Annex B). Should there be a discrepancy at any point during the Hearing, the Secretary of the Tribunal will alert the Tribunal, and the Tribunal will promptly address the matter. A list of the Hearing Participants can be viewed in Zoom’s “Participants” tab. The Zoom moderator will also have an Active User Participants List which must match the Final List of Participants. This should take care of any privacy concerns.

3. Connectivity

53. To improve operation of the Zoom platform, the Parties are advised to keep the number of video connections to a minimum and to Active Participants only. Passive Participants should preferably join the meeting through their computer but connecting only their audio (i.e. turning off their video).

54. All Hearing Participants shall use the “mute microphone” function when not speaking to reduce background noise and to avoid interference with the audio recording.

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4. Equipment and Set Up

55. For optimum sound quality, especially for the audio recording and the transcription, ICSID highly recommends that the Active Participants use a headset equipped with a microphone and connected through the USB or “mic” jack of the computer or laptop that they use for the Zoom videoconference. Internal microphones do not give as good a sound quality as external microphones. If not available, Active Participants are asked to speak close to the microphone of the computer or laptop from which they are connected to the Zoom session.

56. While not indispensable, Hearing Participants are advised to have at least two screens, and preferably three (it can be one device with multiple screens or a combination of devices including tablets) to facilitate simultaneous viewing of: (i) the Zoom video connection; (ii) the online real time transcript; and (iii) offline documents.

57. Hearing Participants joining via video shall avoid sitting with a window or source of light behind them because this darkens their image on screen.

5. Break-Out Rooms

58. Sparq will arrange for Zoom break-out rooms for each Party and the Tribunal, which shall be separate from the Zoom virtual Hearing Room. Each Party shall make its own arrangements for use of any other separate channel of communication to handle internal communications.

On behalf of the Tribunal

Signature

Prof. Luca G. Radicati di Brozolo
President of the Tribunal
22 October 2021
Amended 28 October 2021

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Annex A

Agenda

THE LOPEZ-GOYNE FAMILY TRUST AND OTHERS

v.

REPUBLIC OF NICARAGUA

(ICSID CASE NO. ARB/17/44)

AGENDA

Hearing

15 to 20 November 2021
Videoconference

Day 1: Monday, 15 November 2021

TIME (EST) PROCEDURAL STEP
Morning Claimants’ Opening Statement
Afternoon Respondent’s Opening Statement

Day 2: Tuesday, 16 November 2021

TIME (EST) PROCEDURAL STEP
Morning Examination of Mr. Michael Goyne
Afternoon Examination of Mr. Raymond Gerald Bailey
Examination of Ms. Lorena Lanza

Day 3: Wednesday, 17 November 2021

TIME (EST) PROCEDURAL STEP
Morning Examination of Ms. Verónica Artiles
Examination of Mr. Graeme Phipps
Afternoon Examination of Mr. Eryel Monterrey
Examination of Mr. James Charuk

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Day 4: Thursday, 18 November 2021

TIME (EST) PROCEDURAL STEP
Morning Examination of Ms. Petrona Gago
Examination of Ms. Ana Teresa Rizo
Afternoon Examination of Reserve Analysts Associates
Examination of Ryder Scott

Day 5: Friday, 19 November 2021

TIME (EST) PROCEDURAL STEP
Morning Examination of Compass Lexecon
Examination of Quadrant Economics
Afternoon Examination of Ramboll
Examination of ERM

Day 6: Saturday, 20 November 2021

TIME (EST) PROCEDURAL STEP
Morning Claimants’ Closing Statement
Respondent’s Closing Statement

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Annex B

List of Participants

THE LOPEZ-GOYNE FAMILY TRUST AND OTHERS

v.

REPUBLIC OF NICARAGUA

(ICSID CASE NO. ARB/17/44)

AGENDA

Hearing

15 to 20 November 2021
Videoconference

Name Role/ Affiliation Time zone Active speaker or not Email address/ Phone number

TRIBUNAL

Mr. Luca Radicati di Brozolo President CEST Active Speaker [email protected]
Mr. José Martínez de Hoz Arbitrator ART Active Speaker [email protected]
Prof. Brigitte Stern Arbitrator CEST Active Speaker [email protected]

TRIBUNAL ASSISTANT

Mr. Gregorio Baldoli Assistant to the President of the Tribunal CEST [email protected]

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ICSID SECRETARIAT

Ms. Catherine Kettlewell Secretary of the Tribunal EST [email protected]
Ms. Ivania Fernandez Paralegal EST [email protected]

CLAIMANTS

Counsel:
Mr Jean Paul Dechamps Claimants’ counsel GMT/ART [TBC] Active Speaker [email protected]
Mr Gustavo Topalian Claimants’ counsel ART Active Speaker [email protected]
Dr Tariq Baloch Claimants’ counsel GMT/ART [TBC] Active Speaker [email protected]
Mr Pablo Jaroslavsky Claimants’ counsel ART [email protected]
Mr Juan Ignacio Gonzalez Mayer Claimants’ counsel [TBC] [email protected]
Mr Marcos Sassot Claimants’ counsel ART [email protected]
Ms Sofía Ottaviano Claimants’ counsel ART [email protected]
Mr Juan Pablo Blasco Claimants’ counsel ART [email protected]
Mr Noel Vidaurre Argüello* Claimants’ counsel CST [email protected]
Mr Pastor Lovo Castellon Claimants’ counsel CST [email protected]
Party representatives and witnesses:
Mr Michael Goyne Claimant – Claimants’ witness MST Active Speaker
Mr Raymond Gerald Bailey Claimant – Claimants’ witness MST Active Speaker

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Ms Emily López-Goyne Claimant MST
Experts:
Mr Allen Barron (Reserve Analysts Associates, Inc) Expert witness CST Active Speaker [email protected]
Mr. Kevin Lant Assistant to expert witness CST [email protected]
Mr Nicolas Gwyther (ERM) Expert witness CST Active Speaker [email protected]
Mr Alejandro De Jesús (ERM) Expert witness CST Active Speaker [email protected]
Dr Doug MacNair (ERM) Expert witness EST Active Speaker [email protected]
Ms Carla Chavich (Compass Lexecon) Expert witness EST Active Speaker [email protected]
Mr Michael Seelhof (Compass Lexecon) Expert witness EST Active Speaker [email protected]
Mr. Stephen Hurley (Compass Lexecon) Assistant to expert witnesses EST [email protected]

RESPONDENT

Counsel:
Mr. Paul S. Reichler Respondent’s counsel EST Active Speaker [email protected]
Ms. Tafadzwa Pasipanodya Respondent’s counsel EST Active Speaker [email protected]
Ms. Christina Beharry Respondent’s counsel EST Active Speaker [email protected]
Mr. Diego Cadena Respondent’s counsel EST Active Speaker [email protected]

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Ms. Madeleine K. Rodriguez Respondent’s counsel EST Active Speaker [email protected]
Mr. Peter Shults Respondent’s counsel EST Active Speaker [email protected]
Mr. Nicholas Renzler Respondent’s counsel EST Active Speaker [email protected]
Ms. Eva Paloma Treves Respondent’s counsel EST Active Speaker [email protected]
Ms. Elisa Méndez Bräutigam Respondent’s counsel EST Active Speaker [email protected]
Party representatives:
Jorge Vásquez Respondent’s representative [TBC] [email protected]
Ing. Maria Jazmín Pérez Respondent’s representative CST [email protected]
Witnesses:
Ms. Lorena Lanza Witness [TBC] Active Speaker [email protected]
Ms. Verónica Artiles Witness CST Active Speaker [email protected]
Ms. Petrona Gago Witness [TBC] Active Speaker [email protected]
Mr. Eryel Monterrey Witness [TBC] Active Speaker [email protected]
Mr. James Charuk Witness EST Active Speaker [email protected]
Mr. Graeme Phipps Witness EST Active Speaker [email protected]
Experts:
Mr. Guale Ramirez (Ryder Scott) Expert witness EST Active Speaker [email protected]

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Mr. Dan Olds (Ryder Scott) Expert witness EST Active Speaker [email protected]
Mr. Miles Palke (Ryder Scott) Expert witness EST Active Speaker [email protected]
Mr. Stephen Phillips (Ryder Scott) Expert witness EST Active Speaker [email protected]
Mr. Daniel Flores (Quadrant) Expert witness EST Active Speaker [email protected]
Mr. Ivan Vásquez (Quadrant) Assistant to Expert witness EST [email protected]
Mr. Francisco Sánchez (Quadrant) Assistant to Expert witness EST [email protected]
Ms. Ana Teresa Rizo Expert witness EST Active Speaker [email protected]
Scott E. MacDonald (Ramboll) Expert witness EST Active Speaker [email protected]
Pieter N. Booth (Ramboll) Expert witness EST Active Speaker [email protected]

COURT REPORTERS

David Kasdan Court Reporter (English)
Dante Rinaldi Court Reporter (Spanish)

INTERPRETERS

Amalia Thaler de Klemm [email protected]
Jesus Getan Bornn [email protected]
Luis Arango [email protected]
Andrew Roth

TECHNICAL SUPPORT STAFF

Name Affiliation to Case
[TBC] Sparq Operator