1. INTRODUCTION 

1.1 The Republic of Indonesia (the "Respondent" or the "State") is hereby requested to produce the Documents described below to Churchill Mining PLC and Planet Mining Pty Ltd (the "Claimants"). 

2. GENERAL OBSERVATIONS 

2.1 On 11 March 2015, two days before the Claimants were due to file their document production request in accordance with the schedule for the document authenticity phase set out at Annex 1 to the Tribunal's letter dated 4 March 2015 (the "Claimants' First DPR"), the State applied for leave to submit additional documents, including witness statements and a further handwriting examination report, into evidence ("State's Application for Leave"). 

2.2 While the Claimants did not oppose the State's Application for Leave, they reserved their rights to make further requests for the production of Documents in respect of the items of evidence that were to be subject of the State's Application for Leave (Claimants' First DPR, para. 4.1). 

2.3 On 3 April 2015, the State submitted a supplemental witness statement for each of Mr. Ishak and Ms. Nurohmah, and a witness statement for each of Bambang Setiawan and Chaerul Djalil. 

2.4 On 27 April 2015, the State submitted Mr. Epstein's fourth forensic handwriting examination report dated 27 April 2015 ("Fourth Handwriting Examination Report"). 

2.5 In the exercise of the rights they reserved, the Claimants now file this second document production request (the "Claimant's Second DPR") in response to the additional forgery allegations asserted by the State in its Application for Leave and its supporting documents, the witness statements and the Fourth Handwriting Report.