Applicants’ Memorial on Annulment

Opening of the document

INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES GABRIEL RESOURCES LTD. AND G ABRIEL RESOURCES (JERSEY) L TD. ICSID CASE NO. ARB/15/31 MEMORIAL ON ANNULMENT Counsel for Applicants MEMORIAL ON ANNULMENT TABLE OF CONTENTS THE ENTIRE AWARD MUST BE ANNULLED ON THE GROUNDS OF ICSID A. The Tribunal Was Not Properly Constituted and the Award Therefore Must Be Annulled Because Any Reasonable and Informed Third Party Justifiably Would Doubt That the Tribunal Could Fairly and Impartially Resolve the Prof. Douglas took on as a client Friends of the Earth, a longstanding public opponent of the Roşia Montană Project and of Concurrently with Prof. Douglas’ undisclosed work for Friends of the …