INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES
Continental Gold Inc.
v.
Republic of Colombia
(ICSID Case No. ARB/24/25)
Members of the Tribunal
Prof. Dr. Klaus Sachs, President of the Tribunal
Ms. Elisabeth Eljuri, Arbitrator
Ms. Loretta Malintoppi, Arbitrator
Assistant to the Tribunal
Mr. Marcus Weiler
Secretary of the Tribunal
Ms. Elisa Méndez Bräutigam
14 April 2025
[Page 1]
1. On 4 and 7 April 2025, the Parties advised the Tribunal that they had agreed to several modifications to the procedural calendar.
2. On 9 April 2025, the Tribunal informed the Parties that it agreed in principle with the proposed modifications, except for the deadline for the decision on the Parties’ document production requests under scenario 1. The Tribunal invited the Parties to submit a new calendar taking into account a new deadline for this procedural step and any adjustments to the subsequent deadlines that the Parties might consider necessary.
3. On 9 and 10 April 2025, the Parties provided a revised procedural calendar.
4. The Tribunal hereby adopts the Parties’ revised procedural calendar as reflected below in Annex A.
On behalf of the Tribunal,
Signature
Professor Dr. Klaus Sachs
President of the Tribunal
Date: 14 April 2025
[Page 2]
| Description | By | Days | Dates |
| Initial Phase | |||
| First Procedural Meeting | All | 5 March 2025 | |
| Memorial, with any Witness Statement(s) and Expert Report(s) | Claimant | 86 (336 days after the RfA) | 30 May 2025 |
| Counter-Memorial, including any objection to the Tribunal’s jurisdiction and/or counterclaim, with any Witness Statement(s) and Expert Report(s) | Respondent | 150 | 27 October 2025 |
| Document Production Phase | |||
| Request to Produce | Claimant and Respondent | 28 | 24 November 2025 |
| Production of Non-Objected Documents and Objections to Produce | Claimant and Respondent | 21 | 15 December 2025 |
| Response to Objections to Produce and reasoned applications for an order on production of documents in the form of a Stern Schedule (Annex C) | Claimant and Respondent | 21 | 5 January 2026 |
| Decision on Request to Produce | Tribunal | 21 | 2 February 2026 |
| Production as ordered | Claimant and Respondent | 21 | 23 February 2026 |
| Additional Written Pleadings | |||
| Reply with any Reply Witness Statement(s) and Expert Report(s) | Claimant | 60 | 24 April 2026 |
| Rejoinder with any Rejoinder Witness Statement(s) and Expert Report(s) | Respondent | 90 | 23 July 2026 |
| Rejoinder on Jurisdictional Objections with any Rejoinder Witness Statement(s) and Expert Report(s) (if applicable) | Claimant | 45 | 6 September 2026 |
[Page 3]
| Oral Pleading Phase | |||
| Notification of witnesses and experts for the examination at the Hearing | Claimant and Respondent | Six weeks prior to the Hearing | Q4 2026 |
| Submission of a joint proposal on a daily schedule for the Hearing | Claimant and Respondent | Five weeks prior to the Hearing | |
| Pre-hearing organizational conference | All | Four weeks prior to the Hearing | |
| Hearing | All | ||
| Description | By | Days | Dates |
| Initial Phase | |||
| First Procedural Meeting | All | 5 March 2025 | |
| Memorial, with any Witness Statement(s) and Expert Report(s) | Claimant | 86 (336 days after the RfA) | 30 May 2025 |
| Respondent’s Identification of Preliminary Objections and Request for Bifurcation | Respondent | 40 | 9 July 2025 |
| Claimants’ Response to the Request for Bifurcation | Claimant | 40 | 18 August 2025 |
| Tribunal’s Decision on Bifurcation | Tribunal | 45 | 2 October 2025 |
| Counter-Memorial, including any objection to the Tribunal’s jurisdiction and/or counterclaim, with any Witness Statement(s) and Expert Report(s) | Respondent | 150 (+7 days Christmas break) | 8 March 2026 |
| Document Production Phase | |||
| Request to Produce | Claimant and Respondent | 28 | 5 April 2026 |
[Page 4]
| Production of Non-Objected Documents and Objections to Produce | Claimant and Respondent | 21 | 26 April 2026 |
| Response to Objections to Produce and reasoned applications for an order on production of documents in the form of a Stern Schedule (Annex C) | Claimant and Respondent | 21 | 17 May 2026 |
| Decision on Request to Produce | Tribunal | 21 | 7 June 2026 |
| Production as ordered | Claimant and Respondent | 21 | 28 June 2026 |
| Additional Written Pleadings | |||
| Reply with any Reply Witness Statement(s) and Expert Report(s) | Claimant | 60 | 27 August 2026 |
| Rejoinder with any Rejoinder Witness Statement(s) and Expert Report(s) | Respondent | 90 | 25 November 2026 |
| Rejoinder on Jurisdictional Objections with any Rejoinder Witness Statement(s) and Expert Report(s) (if applicable) | Claimant | 45 (+7 days Christmas break) | 16 January 2027 |
| Oral Pleading Phase | |||
| Notification of witnesses and experts for the examination at the Hearing | Claimant and Respondent | Six weeks prior to the Hearing | Q1-Q2 2027 |
| Submission of a joint proposal on daily schedule for the Hearing | Claimant and Respondent | Five weeks prior to the Hearing | |
| Pre-hearing organizational conference | All | Four weeks prior to Hearing | |
| Hearing | All | ||
[Page 5]
| Description | By | Days | Dates |
| Initial Phase | |||
| First Procedural Meeting | All | 5 March 2025 | |
| Memorial, with any Witness Statement(s) and Expert Report(s) | Claimant | 86 (336 days after the RfA) | 30 May 2025 |
| Respondent’s Identification of Preliminary Objections and Request for Bifurcation | Respondent | 40 | 9 July 2025 |
| Claimants’ Response to the Request for Bifurcation | Claimant | 40 | 18 August 2025 |
| Tribunal’s Decision on Bifurcation | Tribunal | 45 | 2 October 2025 |
If the Tribunal grants bifurcation, a further procedural calendar will be set for the first phase and, depending on its outcome – for the second phase (if any) of this arbitration