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PCA Case No. 2021-26

IN THE MATTER OF AN ARBITRATION UNDER
ANNEX 14-C OF THE CANADA-UNITED STATES-MEXICO AGREEMENT
(“CUSMA”), CHAPTER 11 OF THE NORTH AMERICAN FREE TRADE
AGREEMENT (“NAFTA”),
AND THE 2013 UNCITRAL ARBITRATION RULES

- between -

WINDSTREAM ENERGY LLC

(the “Claimant”)

- and -

THE GOVERNMENT OF CANADA

(the “Respondent”, and together with the Claimant, the “disputing parties”)


PROCEDURAL ORDER NO. 3

Procedural Calendar


The Arbitral Tribunal
Ms Wendy Miles KC (Presiding Arbitrator)
Prof. John Gotanda
Rt. Hon. Beverly McLachlin

Administering Authority
Permanent Court of Arbitration

Tribunal Secretary
Mr José Luis Aragón Cardiel

3 November 2022

[Page 2]

I. BACKGROUND

1. On 13 September 2022, the Tribunal issued Procedural Order No. 2 (Decision on Bifurcation), whereby it denied the Respondent’s request for the bifurcation of the proceedings and directed the disputing parties to confer with a view to agreeing on a joint proposed timetable for the arbitration.

2. On 23 September 2022, the disputing parties submitted a joint proposed timetable for the proceedings.

3. On 26 September 2022, the Tribunal (i) confirmed the disputing parties’ agreed schedule; and (ii) invited the disputing parties to confer and identify potential dates for a hearing in February 2024, as well as to express their preferences regarding the hearing venue.

4. On 29 September 2022, the disputing parties confirmed their availability for a hearing the weeks of 5 February and 12 February 2024. They further expressed their preference to reserve 10 business days for the hearing and for Arbitration Place in Toronto to be the hearing venue.

II. PROCEDURAL CALENDAR

5. Pursuant to the agreement of the Parties, the Tribunal establishes the Procedural Calendar set out in Annex A to this order.

Dated: 3 November 2022

Place of Arbitration: Toronto

Signature

Ms. Wendy Miles QC
(Presiding Arbitrator)

On behalf of the Tribunal

PCA 402642

[Page 3]

Annex A: Procedural Calendar

Event Interval Date
Respondent’s Counter-Memorial on Merits and Damages, including any jurisdictional objections to which the Respondent did not Request Bifurcation with Witness Statement(s) and Expert Report(s) +90 Days from Decision to Deny Bifurcation 12 December 2022 (Monday)
Document Production
Simultaneous requests for document production to the other Party, if any +30 days from the Respondent’s Counter-Memorial 11 January 2023 (Wednesday)
Objections to production, if any +30 days 10 February 2023 (Friday)
Replies to objections to production, if any +21 days 3 March 2023 (Friday)
Responses to replies to objections to production, if any +14 days 17 March 2023 (Friday)
Reasoned applications for an order on production of documents in the form of a Redfern Schedule (Annex II), if necessary +14 days 31 March 2023 (Friday)
Tribunal’s decision on document production, if necessary + 1 month 1 May 2023 (Monday)
Production of documents +30 days 31 May 2023 (Wednesday)
Further Written Pleadings
Claimant’s Reply Memorial with any Reply Witness Statement(s) and Expert Report(s) +75 days 14 August 2023 (Monday)
Respondent’s Rejoinder Memorial with any Rejoinder Witness Statement(s) and Expert Report(s) + 75 days 30 October 2023 (Monday)
Submissions of United States and Mexico Pursuant to NAFTA Article 1128 +30 days 29 November 2023 (Wednesday)
Responses to 1128 Submissions +15 days 14 December 2023 (Thursday)
Oral Pleadings
Pre-hearing Conference Approximately 2 months before hearing TBD
Oral Hearing - 5-16 February 2024 (reserved) (excluding the intervening weekend) (Arbitration Place, Toronto)

PCA 402642