This HTML version is machine-generated. Always consult the original document.Original document (PDF), opens in new tab

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

9REN Holding S.À.R.L.,

Plaintiff,

v.

Kingdom of Spain,

Defendant.

The Hon. Tanya S. Chutkan
Case No. 19-cv-1871

Joint Status Report

Pursuant to the Court’s Minute Order dated September 30, 2020, Plaintiff, 9REN Holding S.À.R.L. (“9REN”), and Defendant, the Kingdom of Spain ("Spain") (collectively, the “Parties”), submit this Joint Status Report regarding the ongoing annulment proceedings in 9Ren Holding S.a.r.l. v. Kingdom of Spain, ICSID Case No. ARB/15/15 (“Annulment Proceedings”).

On April 7, 2020, the ICSID Secretary-General registered Spain's Application for Annulment of the Award dated May 31, 2019 (“Award”) issued by the Arbitral Tribunal in 9Ren Holding S.a.r.l. v. Kingdom of Spain, ICSID Case No. ARB/15/15, and provisionally stayed enforcement of the Award. The Secretary-General also requested the Chairman of the Administrative Council of ICSID to appoint the members of the ad hoc Committee (“Committee”) constituted to decide Spain's Application for Annulment.

On June 8, 2020, the Committee was constituted in accordance with Article 52(3) of the ICSID Convention.

On July 20, 2020, the Committee, together with the Parties, held the first procedural session of the Annulment Proceedings by video conference.

[Page 2]

On July 20, 2020, Spain filed a request to continue the stay of enforcement of the Award.

On July 23, 2020, the Committee issued Procedural Order No. 1 concerning procedural matters for the Annulment Proceedings.

On August 3, 2020, 9REN filed its observations (“9REN’s Observations”) on Spain’s request to continue the stay of enforcement of the Award.

On August 13, 2020, Spain filed a response (“Spain’s Response”) to 9REN’s Observations.

On August 24, 2020, 9REN filed its further observations on Spain’s Response.

The Parties have fully briefed Spain's application to continue the provisional stay of enforcement, and are awaiting a decision from the Committee on the Parties’ written submissions.

Briefing on the merits of Spain's Application for Annulment is scheduled to begin on October 30, 2020, with the filing of Spain's Memorial, and to conclude on July 27, 2021, with the filing of 9REN’s Rejoinder. The Committee has scheduled a hearing for oral arguments in the Annulment Proceedings to be held in the week of September 27, 2021.

No other developments have occurred in the Annulment Proceedings, which remain pending before the ICSID Committee.

Dated: October 30, 2020

Respectfully submitted,

KING & SPALDING LLP

By: /s/ James E. Berger
James E. Berger (D.C. Bar No. 481408)
Charlene C. Sun (D.C. Bar No. 1027854)

SQUIRE PATTON BOGGS (US) LLP

By: /s/ Miriam K. Harwood
Miriam K. Harwood (PHV granted
12/23/2019)

[Page 3]

1185 Avenue of the Americas
New York, NY 10036-4003
Tel: (212) 556-2200
Fax: (212) 556-2222
Email: [email protected]
Email: [email protected]

Attorneys for Plaintiff
9REN Holding S.À.R.L.

Eridania Perez-Jaquez (PHV granted
01/15/2019)
Carlos E. Guzman Plascencia (PHV
granted 01/15/2019)
30 Rockefeller Plaza, 23rd Floor
New York, New York, 10112
Tel.: (212) 872-9852
Fax: (212) 872-9815
Email: [email protected]
[email protected]
[email protected]

-and-

Mitchell R. Berger (D.C. Bar No. 385467)
2550 M Street, N.W.
Washington, D.C. 20037
Tel.: (202) 457-6000
Fax: (202) 457-6315
Email: [email protected]

-and-

Raúl B. Mañón (PHV granted 01/15/2019)
200 South Biscayne Boulevard, Suite 4700
Miami, Florida 33131
Tel: 305-577-7000
Fax: 305-577-7001
Email: [email protected]

Attorneys for Defendant
The Kingdom of Spain

[Page 4]

CERTIFICATE OF SERVICE

I hereby certify that on October 30, 2020, I electronically filed the foregoing pleading with the Clerk of Court using the CM/ECF system and thereby served electronic copy upon counsel of record.

/s/ Miriam K. Harwood