Dear Mrs. Kinnear: 

1. I am addressing you to propose the disqualification, in accordance with Article 57 of the Convention on the Settlement of Investment Disputes between States and Nationals of Other States (“ICSID Convention”) and Rule 9 of the Rules of Procedure for Arbitration Proceedings (“Arbitration Rules”), of the President of the Tribunal, Mr. Pierre Tercier, and the arbitrator appointed by Claimants, Mr. Albert Jan van den Berg (hereinafter collectively referred to as the “majority of the Tribunal” or -“challenged arbitrators”). The disqualification is grounded upon the manifest lack of the qualities required by Article 14(1) of the ICSID Convention, evidenced by different circumstances described herein below and which manifestly preclude the challenged arbitrators from being relied upon to exercise independent judgment. 

2. Further, the Argentine Republic expressly reserves its right to expand the arguments set forth in this Request for Disqualification, in particular after receiving the explanations of the challenged arbitrators in accordance with Arbitration Rule 9 (3), if any.