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INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES

Eco Oro Minerals Corp.

Claimant

v.

Republic of Colombia

Respondent

(ICSID Case No. ARB/16/41)


PROCEDURAL ORDER No. 4


Members of the Tribunal
Mrs. Juliet Blanch, President of the Tribunal
Professor Horacio A. Grigera Naón, Arbitrator
Professor Philippe Sands, Arbitrator

Secretary of the Tribunal
Mrs. Ana Constanza Conover Blancas

Assistant to the President of the Tribunal
Mr. João Vilhena Valério

10 October 2018

[Page 1]

I. PROCEDURAL BACKGROUND

1. By letter of 26 September 2018, Respondent filed a request for a 60-day extension of the deadline set out in Procedural Order No. 3 to submit its Counter-Memorial on the Merits and Memorial on Jurisdiction (the “Extension Request”).

2. By communication of 27 September 2018, the Tribunal invited Claimant to submit observations regarding the Extension Request. On 1 October 2018, Claimant submitted its observations regarding the Extension Request.

3. By communication of 2 October 2018, Respondent sought leave from the Tribunal to submit a brief response to Claimant’s letter of 1 October 2018. On the same date, the Tribunal granted Respondent’s request and invited Claimant to respond to Respondent’s submission no later than by 5 October 2018.

4. On 3 October 2018, Respondent submitted its observations regarding Claimant’s letter of 1 October 2018. Subsequently, on 5 October 2018, Claimant submitted its observations regarding Respondent’s letter of 3 October 2018.

5. On 8 October 2018, Respondent submitted an additional communication in connection with the Extension Request, to “bring to [the Tribunal’s] attention new material facts that occurred following [Respondent’s] letter of 3 October 2018.”

II. ORDER

6. The Tribunal has reviewed and considered Respondent’s Extension Request, which is mainly based on alleged delays in the preparation of its Counter-Memorial on the Merits and Memorial on Jurisdiction arising out of a government transition process known as empalme, as well as Claimant’s arguments by which it objects to the Extension Request.

[Page 2]

7. The Tribunal does not favor procedural delays and it disapproves of persistent revisions to the timetable of the proceeding, which was originally set out in Procedural Order No. 1 of 30 November 2017 and later revised in Procedural Order No. 3 of 29 August 2018.

8. Nevertheless, in view of the seeming impossibility of the Respondent to be able to complete its filing in under sixty days, the Tribunal decides to grant the Extension Request.

9. The granting of Respondent’s Extension Request constitutes a final extension. In no circumstances will the Tribunal allow another extension for the filing of Respondent’s Counter-Memorial on the Merits and Memorial on Jurisdiction.

10. Claimant will be allowed the same 60-day extension for the filing of its Reply on the Merits and Counter-Memorial on Jurisdiction, if so required.

11. In view of the above, Annex A to Procedural Order No. 1 is hereby amended as follows:

Annex A – Procedural Calendar

Eco Oro Minerals Corp. v. Republic of Colombia
(ICSID Case No. ARB/16/41)

[...]

SCENARIO 3

The following timetable shall apply in the event that objections to jurisdiction are made in response to the memorial on the merits, and there is a request for bifurcation which is refused.

[Page 3]

[Page 4]

Description Party /
Tribunal
Period of Time Due Date
Counter-Memorial on the Merits and Memorial on Jurisdiction Respondent +60 days from
25 October 2018
24 December 2018
Cut-off date for submission of applications for leave to file a Non-Disputing Party submission Non-Disputing Parties +5 days from Counter-Memorial on Merits and Memorial on Jurisdiction 31 December 2018
Description Party /
Tribunal
Period of Time Due Date
Comments on the applications from Non-Disputing Parties seeking leave to file submissions Parties +21 days from applications from Non-Disputing Parties 21 January 2019
Requests for Production of Documents Parties +30 days from the Counter-Memorial on the Merits and Memorial on Jurisdiction 23 January 2019
Objections to Production Requests and Production of Uncontested Documents Parties +14 days from the Requests for Production of Documents 6 February 2019
Decision concerning applications from Non-Disputing Parties Tribunal +21 days from the Parties’ Comments on the applications from Non-Disputing Parties seeking leave to file submissions 11 February 2019
Responses to Objections to Production Requests Parties + 14 days from the Objections to Production Requests 20 February 2019
Ruling on Parties’ Requests for Production of Documents Tribunal + 14 days from Responses to Objections to Productions Requests 6 March 2019
Deadline to file Non-Disputing Party submission Non-Disputing Parties +30 days from the Tribunal’s Decision concerning applications from Non-Disputing Parties 13 March 2019
Document Production in accordance with the Tribunal’s Rulings Parties + 21 days from the Ruling on Parties’ Requests for Production of Documents 27 March 2019
Reply on the Merits and Counter-Memorial on Jurisdiction Claimant +[140/200] days from the Counter-Memorial on the Merits and Memorial on Jurisdiction If no extension is requested by Claimant under paragraph 10 supra (“Option A”):
13 May 2019
If Claimant requests an extension under paragraph 10 supra (“Option B”): 12 July 2019
Description Party /
Tribunal
Period of Time Due Date
Rejoinder on the Merits and Reply on Jurisdiction Respondent +140 days from the Reply on the Merits and Counter-Memorial on Jurisdiction Option A: 30 September 2019
Option B: 29 November 2019
Rejoinder on Jurisdiction Claimant +60 days from Rejoinder on the Merits and Reply on Jurisdiction Option A: 29 November 2019
Option B: 28 January 2020
Witness notification Claimant & Respondent 45 days before the Hearing Option A: 6 December 2019
Option B: To be determined by the Tribunal, in consultation with the Parties (“TBD”)
Pre-Hearing Organizational Meeting All 30 days before the Hearing Option A: 20 December 2019
Option B: TBD
Hearing All within 60 to 120 days from Rejoinder on Jurisdiction Option A: in the period between 20-31 January 2020
Option B: TBD

On behalf of the Tribunal,

[Signed]

Mrs. Juliet Blanch
President of the Tribunal
Date: 10 October 2018