Barbados v Trinidad and Tobago, Text of Counter-Memorial (Trinidad and Tobago)

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In its Memorial of 30 October 2004, Barbados made a new claim to a maritime boundary.  In five rounds of negotiations on the maritime boundary, Barbados had never depicted this or indeed any boundary claim.  In four rounds of negotiations on a new bilateral fisheries access agreement, Barbados had never indicated that what was really under consideration was whether Trinidad and Tobago would be entitled to some share in the  living natural resources of  the Barbadian EEZ, 13 miles  off  the coast of Tobago-living resources which Barbados has never purported to regulate or conserve. Barbados’ claim had never been shown on any map. Barbados’ claim had never been articulated in words either.  It came new-minted with the Memorial.