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INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES

Cyrus Capital Partners, L.P. and Contrarian Capital Management, LLC
(Claimants)

v.

United Mexican States
(Respondent)

(ICSID Case No. ARB/23/33)

PROCEDURAL ORDER No. 3
Revised Procedural Calendar

Members of the Tribunal
Rt. Hon. Lord Collins of Mapesbury, LLD, FBA, President of the Tribunal
Dr. David J.A. Cairns, Arbitrator
Prof. Zachary Douglas, KC, Arbitrator

Secretary of the Tribunal
Ms. Veronica Lavista

20 August 2024

[Page 2]

  1. On 15 August 2024, the Parties communicated to the Tribunal that they had agreed to an extension of 10 days for the Claimants’ presentation of the Counter-Memorial on Jurisdiction. In addition to changing the trigger date for the Reply on Jurisdiction.
  2. The Tribunal agrees with the changes proposed by the Parties and adopts the revised Procedural Calendar as reflected below.
No. Event Author Date Interval
1. Memorial on Jurisdiction Respondent Tuesday, 4 June 2024 75 days from the First Session
2. Counter-Memorial on Jurisdiction Claimants Thursday, 29 August 2024 85 days from Memorial on Jurisdiction
3. Requests for Document Production Claimants and Respondent Thursday, 12 September 2024 2 weeks from Counter-Memorial on Jurisdiction
4. Production of non-objected documents and Objections to the Requests for Document Production (if any) Claimants and Respondent Thursday, 10 October 2024 4 weeks from Requests for Document Production
5. Reply to the Objections to the Requests for Document Production Redfern Schedule provided to Tribunal Claimants and Respondent Thursday, 7 November 2024 4 weeks from production of non-objected documents and objections
6. Decision of Tribunal Tribunal Thursday, 5 December 2024 4 weeks from Reply to Objection
7. Simultaneous production of documents ordered by Tribunal Claimants and Respondent Thursday, 2 January 2025 4 weeks from Decision of Tribunal
8. Reply on Jurisdiction Respondent Monday, 3 March 2025 60 days from simultaneous production of documents ordered by Tribunal
9. Rejoinder on Jurisdiction Claimants Friday, 2 May 2025 60 days from Reply on Jurisdiction

[Page 3]

No. Event Author Date Interval
10. Applications for leave to file non-disputing party (amicus) submissions, if any TBD Monday, 19 May 2025 15 days from Rejoinder on Jurisdiction
11. Submissions under NAFTA Article 1128, if any TBD Monday, 19 May 2025 15 days from Rejoinder on Jurisdiction
12. Comments on applications for leave to file non-disputing party (amicus) submissions, if any Claimants and Respondent Monday, 9 June 2025 21 days from applications for leave to file non-disputing party submissions
13. Comments on NAFTA Article 1128 submissions Claimants and Respondent Monday, 9 June 2025 21 days from submissions under NAFTA Article 1128
14. Decision on applications for leave to file non-disputing party (amicus) submissions, if any Tribunal Tuesday, 24 June 2025 15 days from Comments
15. Parties to identify witnesses and experts for cross-examination All TBD
16. Pre-Hearing Conference All TBD
17. Hearing on Jurisdiction All TBD
18. Post-Hearing Submission Parties TBD
19. Cost statements Parties TBD

On behalf of the Tribunal,

Signature

Rt. Hon. Lord Collins of Mapesbury, LLD, FBA
President of the Tribunal
Date: 20 August 2024