[Page 2]
Saunders Law
Ltd
Olga Boltenko
Legal Counsel
Permanent Court of Arbitration
Peace Palace, Carnegieplein 2
2517 KJ The Hague
The Netherlands
Email - [email protected].
26 February 2013
Our Ref : SKK/BAH0005-1-0/4653
Your Ref : PCA Case No – 2012-07
Dear Ms Boltenko
Re: PCA Case no 2012-07 – Mohamed Abdel Raouf Bahgat v. The Arab Republic of Egypt - In arbitration held under Bilateral Investment Treaties Between Finland and Egypt dated 5 May 1980 and March 2004 and under the UNCITRAL Arbitration Rules
We have considered the contents of the Bifurcation application made by Egypt in this arbitration and are instructed to advise as follows.
The Respondent's application questioning the Tribunal's jurisdiction is without any merit and the Claimant will respond to this application in due course. In the meantime bearing in mind Article 21.4 of the UNCITRAL Arbitration rules, with a view to reducing avoidable expenses and costs and entirely without prejudice to our client's rights and claims, we write to advise that the Claimant does not oppose the Respondent's application for bifurcation.
In accordance with the terms of the Procedural Order No 1 we therefore look forwarding to receiving the Respondent's Memorial on Jurisdiction by 15 July 2013 upon receipt of which the Claimant is required to serve his Counter Memorial by 30 August 2013.
Yours sincerely
Signature
Subir Karmakar
SAUNDERS LAW LTD
| TEL + 44 (0) 20 7632 4300 FAX + 44 (0) 20 7836 7975 |
Essex Hall 1-6 Essex Street London WC2R 3HY |
EMAIL [email protected] DX 37995 Kingsway |
Limited Company No 7636604 registered in England and Wales. Registered office 1-6 Essex Street, London WC2R 3HY
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[Page 3]
Saunders Law
Ltd
Copy to
Professor Rudiger Wolfrum
Email - [email protected]
Presiding Arbitrator
Professor W. Michael Reisman
Email - [email protected]
Arbitrator appointed by Mr Bahgat
Professor Francisco Orrego Vicuna
Email - [email protected]
Arbitrator Appointed by Egypt
And to
Mr Samuel Wordsworth
Email - [email protected]
Professor Andrew Newcombe
Email - [email protected]
Claimant’s Co-Counsel
Counselor Mohamed El-Sheikh
Egyptian State Lawsuits Authority
10th Floor
Mogamaa Building
Tahrir Square
Cairo, Egypt
Email - [email protected]
[email protected]
[email protected]
[email protected]
[email protected]
Mr Christoph Delanoy
Email - [email protected]
| TEL + 44 (0) 20 7632 4300 FAX + 44 (0) 20 7836 7975 |
Essex Hall 1-6 Essex Street London WC2R 3HY |
EMAIL [email protected] DX 37995 Kingsway |
Limited Company No 7636604 registered in England and Wales. Registered office 1-6 Essex Street, London WC2R 3HY
A list of Directors may be inspected at this office. Authorised and Regulated by the Solicitors Regulation Authority. We do not accept service by fax or email.
[Page 4]
Saunders Law
Ltd
Mr Raed Fathallah
Email - [email protected]
Representing Egypt
| TEL + 44 (0) 20 7632 4300 FAX + 44 (0) 20 7836 7975 |
Essex Hall 1-6 Essex Street London WC2R 3HY |
EMAIL [email protected] DX 37995 Kingsway |
Limited Company No 7636604 registered in England and Wales. Registered office 1-6 Essex Street, London WC2R 3HY
A list of Directors may be inspected at this office. Authorised and Regulated by the Solicitors Regulation Authority. We do not accept service by fax or email.