IN ARBITRATION PURSUANT TO THE RULES OF ARBITRATION
OF THE UNITED NATIONS COMMISSION ON INTERNATIONAL TRADE LAW

WESTMORELAND COAL COMPANY

Claimant

vs.

GOVERNMENT OF CANADA,

Respondent

CLAIMANT’S STATEMENT OF COSTS

Lauren F. Friedman
Kevin D. Mohr
Cedric Soule
Rikki Stern
Tamsin Parzen
KING & SPALDING LLP
1185 Avenue of the Americas
34th Floor
New York, NY 10036
Tel: +1 212-556-2100

Counsel for Claimant

14 June 2024

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1. As agreed at the hearing on jurisdiction, Claimant respectfully submits its Statement of Costs.¹ Claimant’s fees and expenses in this arbitration total USD 3,589,624.68, as detailed below:

KING & SPALDING LLP

EXPERT WITNESSES

¹ Tr. Day 2, 321:9, 323:13-22. ↩

² King & Spalding has been engaged by Claimant on a hybrid “capped fee and success fee” basis in relation to the law firm’s investment of time (hours) on this matter. This amount is composed of USD 2,425,000.00 of fees invoiced by King & Spalding on a capped-fee basis, and a further USD 786,552.50 of fees invoiced and payable if Claimant succeeds on jurisdiction. In light of the success fee component, Claimant seeks recovery of the law firm’s time investment in the case in excess of the cap at normal hourly rates. Thus, Claimant seeks USD 3,240,552.50 in legal fees, which equates to King & Spalding’s total time investment in the case at normal hourly rates. ↩

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ARBITRATION EXPENSES

Respectfully submitted,

KING & SPALDING LLP

By:

Signature

Counsel for Claimant