THE PROBLEM

Contents
Document
Page
Fasttrack to CAM-CCBC (31 May 2016) 2
Request for Arbitration (31 May 2016) 3
Claimant’s Exhibit C 1 (Summary Notes of 1 May 2010 by Maryam Filmas) 8
Claimant’s Exhibit C 2 (Development and Sales Agreement with
9
handwritten Addendum)
Claimant’s Exhibit C 3 (E-Mail of 15 January 2015 by Lindbergh) 12
Claimant’s Exhibit C 4 (Witness Statement Mario Lee) 13
Claimant’s Exhibit C 5 (E-Mail of 15 January 2015 by Beinhorn) 14
Claimant’s Exhibit C 6 (E-Mail of 9 February 2015 by Beinhorn) 15
Claimant’s Exhibit C 7 (E-Mail of 10 February 2015 by Lindbergh) 16
Claimant’s Exhibit C 8 (Letter by Equatoriana Central Bank) 17
Power of Attorney by Wright Holding Plc 18
CAM-CCBC’s letter to the Claimant (Receipt of Request of Arbitration -1
June 2016 – Request for Completion)
19
Fasttrack to CAM-CCBC (7 June 2016) 20
Power of Attorney by Wright Ltd 21
CAM-CCBC’s letter to the Respondent (Service of the statement of
claim – 08 June 2016)
22
Answer to Statement of Claim (24 June 2016) 23
Respondent’s Exhibit R 1 (E-Mail of 10 November 2009 by Malmesburry) 27
Respondent’s Exhibit R 2 (E-Mail of 22 October 2009 by Romario) 28
Respondent’s Exhibit R 3 (E-Mail of 1 April 2016 by Beinhorn) 29
Respondent’s Exhibit R 4 (E-Mail of 24 October 2010 by Beinhorn) 30
Respondent’s Exhibit R 5 (E-Mail of 24 October 2010 by Beinhorn) 31
CAM-CCBC’s letter to Arbitrator(s) (Letter to Maracanã 27 June 2016) 32
CAM-CCBC’s letter to the Parties (Letter of 5 July 2016 – Forwarding
answers to Conflict of Interest and Availability Questionnaire)
Order by CAM-CCBC: Appointing President of Tribunal 34
Filled in Questionnaire by President of Tribunal (14 July 2016) 35
CAM-CCBC’s letter to the Arbitrators (21 July 2016) 38
Statement of Independence by President of Tribunal (26 July
2016)
Order by CAM-CCBC (Transmission of the file – 26 July 2016) 40
Terms of Reference (22 August 2016 - excerpts) 41
Respondent’s Request for Security for Costs (6 September 2016) 46
Respondent’s Exhibit R 6 (Article of Carioca Business News 5 September
2016)
48
Letter President of Tribunal – Claimant (8 September 2016) 49
Claimant’s Answer to Request for Security for Costs (16
September 2016)
Claimant’s Exhibit C 9 (Witness Statement Iliena Jaschin) 51
Letter Chairman– Parties (6 October 2016) 52
Procedural Order No 1 (6 October 2016) 53
33
39
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© Association for the Organisation and Promotion of the Willem C. Vis International Commercial Arbitration Moot 1
Prof. Dr. Stefan Kröll