INTRODUCTION 

1. Claimants hereby submit their Reply on their Application for Provisional Measures and Answer to Respondent’s Application for Provisional Measures (the “Reply”). In this submission, Claimants will only address the issues that are relevant for purposes of the present exchange of submissions. For the avoidance of doubt, any issue raised by Respondent which is not specifically and explicitly addressed in the present submission is hereby denied in full, and Claimants reserve their right to address any such issue at a more appropriate stage of the proceedings. 

2. Claimants submit, by way of preliminary remark, that Respondent has chosen to raise a number of issues which are entirely unrelated to the subject-matter of the present dispute. Respondent has done so to divert the Tribunal’s attention away not only from Respondent’s taking of Claimants’ investment – the illegality of which was confirmed by Respondent’s very own Supreme Court on three separate occasions – once reserves had been confirmed by Claimants, but also, and moreover, from the subject-matter of Claimants’ Application for Provisional Measures, namely the retaliatory measures taken against Claimants in blatant disregard of the most basic principles of procedural fairness and due process. 

3. More specifically, Claimants make the following preliminary remarks.