This HTML version is machine-generated. Always consult the original document.Original document (PDF), opens in new tab

INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES


Almaden Minerals Ltd. and Almadex Minerals Ltd.

v.

United Mexican States

(ICSID Case No. ARB/24/23)


PROCEDURAL ORDER No. 4


Members of the Tribunal
Prof. Luca G. Radicati di Brozolo, President of the Tribunal
Mr. Oscar M. Garibaldi, Arbitrator
Prof. Jorge E. Viñuales, Arbitrator

Secretary of the Tribunal
Ms. Anneliese Fleckenstein

Assistant to the Tribunal
Ms. Lucia Pontremoli


September 11, 2025

[Page 2]

I. WHEREAS:

1. On July 25, 2025, the Tribunal issued Procedural Order No. 3, rejecting Respondent's Request for Bifurcation (“PO3”).

2. In compliance with ¶ 49(ii) of PO3, on August 6, 2025, the Parties sent to the ICSID Secretariat a joint proposed procedural calendar for the phases of the proceedings following the Tribunal’s decision on Respondent’s Request for Bifurcation.

3. On August 12, 2025, the Tribunal informed the Parties that it would not be available on the dates proposed for the Hearing and would revert to the Parties with alternative dates, which it did on September 3, 2025.

4. On September 8-9, 2025, the Parties confirmed their availability on the dates proposed by the Tribunal for the Hearing.

II. IN COMPLIANCE WITH ¶ 15.2 OF PO1, THE ARBITRAL TRIBUNAL ISSUES THE FOLLOWING PROCEDURAL ORDER NO. 4:

5. The updated procedural calendar for the next phases of the arbitration, which replaces and supersedes the procedural calendar established in Annex B of PO1, is the following:

Description Party/Tribunal Period Dates
Procedural Order No. 3 Tribunal July 25, 2025
Counter-Memorial Respondent 120 Days from Procedural Order No. 3 November 24, 2025
Production of Documents Phase
Simultaneous exchange of document production requests Parties 21 Days from the Counter-Memorial December 15, 2025
Simultaneous production of requested documents and exchange of objections Parties 32 Days from filing requests for document production January 16, 2026
Response to objections to document production requests and application to tribunal on requests Parties 7 Days from production and objections January 23, 2026
Tribunal’s decisions on requests Tribunal 14 Days from the submission of the Redfern Schedules February 6, 2026
Production of documents ordered by the Tribunal Parties 14 Days from the Tribunal’s decision February 20, 2026

[Page 3]

Description Party/Tribunal Period Dates
Reply Claimants 100 Days from the simultaneous production of requested documents and exchange of objections April 27, 2026
Rejoinder Respondent 100 Days from the Reply August 5, 2026
Requests to Tribunal to file amicus curiae briefs, if any TBD 14 Days from the Rejoinder August 19, 2026
Submissions under CPTPP Art. 9.23(2), if any TBD 14 Days from the Rejoinder August 19, 2026
Notification of witnesses and experts for examination at hearing Parties 28 Days from Rejoinder September 2, 2026
Comments on requests to file amicus curiae briefs, if any Parties 14 Days from the deadline to seek leave from the Tribunal to file amicus curiae briefs September 2, 2026
Comments on CPTPP Art. 9.23(2) submissions, if any Parties 14 Days from the deadline to file submissions under CPTPP Art. 9.23(2) September 2, 2026
Decision on requests for amicus curiae briefs Tribunal 14 Days from the comments on requests to file amicus curiae September 16, 2026
Submission of amicus curiae briefs, if any TBD 21 Days from the Tribunal’s Decision on requests to file amicus curiae briefs October 7, 2026
Comments on submitted amicus curiae briefs, if any Parties 14 Days from submission of amicus curiae briefs October 21, 2026
Pre-hearing organizational meeting All At least five weeks before the Hearing
Hearing All December 14, 2026 – December 18, 2026 (December 19, 2026, in reserve)
Post-hearing submissions Parties TBD TBD
Costs submissions Parties TBD TBD

On behalf of the Tribunal,

Signature

Prof. Luca G. Radicati di Brozolo
President of the Tribunal
Date: September 11, 2025