THE PROBLEM

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T Independence Statement I, the undersigned, appointed by the President of the CAM-CCBC to act as president of the Arbitral Tribunal that will be constituted to decide the dispute between Wright Ltd and SantosD KG in the Arbitration Proceeding Nr. 200/2016/SEC7, Hereby declare, That I have no relationship with the parties or the dispute that may give rise to reasonable doubt as to my independence or impartiality, according to Article 5.2 of the Rules, for all legal purposes and, especially, for those related to this proceeding, therefore being fully independent and impartial to serve as arbitrator. Vindobona, 26 July 2016. Ronald O Zagallo President of the Arbitral Tribunal 39
Arbitration Proceeding Nr. 200/2016/SEC7 Claimant: Wright Ltd Respondent: SantosD KG Order of the President of the CAM-CCBC 1. On 31 May 2016, Wright Ltd (“Claimant”) presented a request for arbitration at CAM-CCBC against SantosD KG (“Respondent”). On 07 June 2016, Claimant presented an amendment to the Request for Arbitration. 2. On 24 June 2016, Respondent presented its Answer to the Request for Arbitration, in accordance with Article 4.3 1 of the Rules. 3. For the constitution of the Arbitral Tribunal, Claimant appointed Ms. Martha Maracanã and Respondent appointed Prof. Lena Chowdry. As provided for in the arbitration clause, the President of the CAM-CCBC appointed Mr. Ronald O Zagallo to act as president on 11 July 2016. 4. All arbitrators answered the CAM-CCBC’s Conflict of Interest and Availability Questionnaire, indicating they are apt to constitute the Arbitral Tribunal. 5. None of the parties raised any objections to the answers and comments provided by the arbitrators in the abovementioned Questionnaire in response to the notification of Article 4.7 2 of the Rules. 6. The arbitrators signed the Statements of Independence, attesting their formal acceptance of the task. 7. Therefore, I confirm the constitution of the Arbitral Tribunal. Accordingly, notify the parties and the Arbitral Tribunal to sign the Terms of Reference within 30 (thirty) days from the receipt of this Order. The Secretariat shall observe compliance of this term. São Paulo, 26 July 2016. Carlos Suplicy de Figueiredo Forbes President of the CAM-CCBC TERMS OF REFERENCE 1 CAM-CCBC Rules, Article 4.3. The Secretariat of the CAM-CCBC will send a copy of the notice and respective documents that support it to the other party, requesting that, within fifteen (15) days, it describe in brief any matter that may be the subject of its claim and the respective amount, as well as comments regarding the seat of arbitration, language, law or rules of law applicable to the arbitration under the contract. 2 CAM-CCBC Rules, Article 4.7. The answers to the Questionnaires and any material facts will be sent to the Parties, after which they will have ten (10) days to submit comments. 40
Page 1 and 2: Twenty Fourth Annual Willem C. Vis
Page 3 and 4: Horace Fasttrack Advocate at the Co
Page 5 and 6: 3. At the time of their sale in 201
Page 7 and 8: 15. Furthermore, Mr Lindbergh state
Page 9 and 10: CLAIMANT’s EXHIBIT C 1 1 May 2010
Page 11 and 12: 3. The BUYER undertakes to purchase
Page 13 and 14: CLAIMANT’s EXHIBIT C 3 Fri 15/01/
Page 15 and 16: CLAIMANT’s EXHIBIT C 5 Fri 15/01/
Page 17 and 18: CLAIMANT’s EXHIBIT C 7 Wed 10/02/
Page 19 and 20: Power of Attorney In the matter of
Page 21 and 22: Horace Fasttrack Advocate at the Co
Page 23 and 24: São Paulo, 08 June 2016. SantosD K
Page 25 and 26: Nomination of Arbitrator and Jurisd
Page 27 and 28: 18. The 0.5% levy by the Central Ba
Page 29 and 30: RESPONDENT’s EXHIBIT R 2 Fr 22/10
Page 31 and 32: RESPONDENT’s EXHIBIT R 4 Mo 24/10
Page 33 and 34: Ms Martha Maracanã 41 Azteca Lane
Page 35 and 36: Arbitration Proceeding Nr. 200/2016
Page 37 and 38: 4. Where do you work or have worked
Page 39: São Paulo, 21 July 2016. Mr. Ronal
Page 43 and 44: 4.2. The Arbitrators have answered
Page 45 and 46: PARTIES: WRIGHT LTD Herein represen
Page 47 and 48: Request for Security for Costs 1 RE
Page 49 and 50: From Mr Ronald O Zagallo President
Page 51 and 52: CLAIMANT’s EXHIBIT C 9 Witness St
Page 53 and 54: CAM-CCBC Arbitration Procedural Ord

THE PROBLEM

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