1. Claimants hereby apply, in the above-referenced arbitration and for the reasons set out below, for provisional measures in order to preserve their rights and avoid a severe aggravation of the dispute, and to respectfully ask that a calendar be set for the exchange of briefs in this respect, in accordance with Article 47 of the ICSID Convention and Rule 39 of the ICSID Arbitration Rules.
2. By way of reminder, on June 25, 2014, EuroGas Inc. (“EuroGas”) and Belmont Resources Inc. (“Belmont”) filed a Request for Arbitration against the Slovak Republic, under the ICSID Convention and Rules.
3. On the very date of the filing of the Request – which had been communicated to Respondent in the course of negotiations1 – JUDr. Roman Púchovsk., Judge on Preliminary Proceedings of the Special Criminal Court in Banská Bystrica, Slovak Republic, issued an “Order for a House Search”2 at the domicile of Ms. Jana Czmoriková, the external accountant of Rozmin sro (“Rozmin”). As explained in the Request for Arbitration, Rozmin is a Slovak Republic-incorporated company in which EuroGas and Belmont hold a 90% shareholding interest and which held exclusive rights for mining activities at the Gemerská Poloma deposit until these were unlawfully revoked in 2005.