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quinn emanuel trial lawyers | london
90 High Holborn, London WC1V 6LJ, United Kingdom | TEL +44 20 7653 2000 FAX +44 20 7653 2100
WRITER'S DIRECT DIAL NO.
+44 20 7653 2227
WRITER'S INTERNET ADDRESS
[email protected]
8 July 2026
By Email Only
Pinna Goldberg
10 Old Square
London WC2A 3SU
[email protected]
[email protected]
FAO: Mr David Goldberg
Dear Sirs,
JSC State Savings Bank of Ukraine (aka JSC “Oschadbank”) v the Russian Federation
(Claim No. CL-2023-000502)
1. We refer to the Consent Order of Mr Justice Bright dated 23 July 2025 and to your letter of 1 July 2026 notifying your client's intention to seek a further stay of these proceedings and enclosing draft application papers in that regard including a draft Consent Order setting out the terms of your client's proposed further stay.
2. In our client's view, your client's appeal in cassation (the Cassation Appeal) against the Judgment of 1 July 2025 of the Paris Court of Appeal in the Renewed French Set-Aside Proceedings (as defined in the November 2024 Order) is an obviously hopeless and misguided action which your client is bound to lose and is aimed purely at generating additional delay.
3. Nevertheless, our client does not consider that it would be an efficient use of Court time or costs to embark on an extended process to contest your client's further stay request, given the expectation that the Cassation Appeal should now proceed promptly to a conclusion. Accordingly, our client is willing in principle, and subject to the remainder of this letter, to consent to a further stay of the present proceedings until the Cour de cassation has rendered its judgment in the Cassation Appeal.
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4. As matters stand, your client's Cassation Appeal are the only relevant proceedings that are pending. Your client's Revision Application dated 19 August 2019 is no longer pending in the arbitration proceedings. To our client's knowledge, although the draft witness statement of Mr Goldberg states that the decisions of the Paris Court of Appeal issued on 23 June 2026 give rise to “the possibility of initiating new revision proceedings before the Tribunal, which would be required to examine afresh the Russian Federation's position that Oschadbank concealed relevant evidence”, your client has yet to take any steps consequent upon those decisions.
5. As such, it plainly would not be appropriate for a stay now to be ordered by reference to “the Defendant's Revision Application dated 19 August 2019 [being] determined anew in the arbitration proceedings” (c.f. the second limb of paragraph 2 of your draft Consent Order). If your client later considers that a new revision application it has subsequently sought to make gives rise to grounds to seek a further or additional stay, our client will respond at the appropriate time, upon receipt of a properly reasoned request supported by draft application papers.
6. For the avoidance of doubt, our client fully reserves its position in respect of:
(i) the effects and consequences of the 23 June 2026 decisions of the Paris Court of Appeal, including (without limitation) as to whether they give rise to any right or entitlement for your client to initiate a new revision application before the arbitral tribunal and, if so, when and on what terms; and
(ii) any new revision application your client may in due course seek to make, which in our client's view would be bound to fail and could, in any event, carry no significance for the enforceability of the Award dated 26 November 2018 (contrary to Mr Goldberg's suggestion otherwise in his draft witness statement).
7. Accordingly, we attach an amended version of your draft Consent Order for your client's consideration. If this is acceptable, please confirm by return and we will provide a signed copy for your counter-signature and to be filed with the Court.
8. Save as aforesaid, we reserve our client's position, including in respect of all other matters addressed by Mr Goldberg in his draft witness statement (which it is not necessary for our client to address at this time in view of the agreement to a further limited stay as set out above).
Yours faithfully,
Signature
QUINN EMANUEL URQUHART & SULLIVAN UK LLP
Enc.