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[email protected] 28014 MADRID [Par courriel] Le 27 avril 2018 Madame Laura Bergamini Secrétaire du Comité ad hoc ICSID Washington D.C. Réf. : Victor Pey Casado et Fondation Président Allende c. République du Chili (Affaire No. ARB-98-2. Nouvel examen- Mémoire en annulation de la Sentence du 13-09-2016) Madame, We have been instructed as members of the legal team representing the Claimant in the case of Victor Pey Casado and President Allende Foundation v. Republic of Chile, ICSID Case No. ARB/98/2. This document is submitted in support of the Memoire en Demande sur l’Annulation de la Sentence du 13 September 2016. As will be clear from previous communications, one of the critical issues being raised by the Claimant, is that there is an appearance of conflict of interest, or potential for there to be an appearance of conflict of interest on the basis that Barrister Members of Essex Court Chambers have acted for the State of Chile in the past, and, are members of the tribunal presiding over it. Whilst, the Respondent has sought to argue that Barristers are self-employed, and are therefore independent of one another, there is a relevant issue in this matter, given the historical and current involvement of Barristers of Essex Court Chambers, and the State of Chile and entities under its control. It is noted that there are serious considerations that the Tribunal is required to deliberate carefully before matters can proceed further.