Pursuant to Procedural Order No. 23, Claimants Chevron Corporation (“Chevron”) and Texaco Petroleum Company (“TexPet”) (collectively “Claimants”) hereby submit their Supplemental Memorial regarding issues relevant to Track 2 of the arbitration proceedings. Claimants incorporate their previous submissions into this Supplemental Memorial on Track 2.1

I. INTRODUCTION AND SUMMARY

1. Claimants’ Track 2 Reply Memorial of June 5, 2013, and prior submissions, detail Claimants’ claims for the Republic of Ecuador’s breaches of its obligations under the Bilateral Investment Treaty and a denial of justice under customary international law.2

2. As previously detailed, Ecuador failed to provide Claimants with effective means of asserting claims and enforcing rights, failed to treat Claimants’ investment fairly and equitably, failed to provide that investment with full protection and security, and treated the investment in an arbitrary and discriminatory manner.3 As addressed in the Track 1 phase of this arbitration, Ecuador further violated the umbrella clause by breaching its contractual obligations to Claimants under the 1995 Settlement Agreement and related releases and agreements.4