On behalf of Murphy Exploration & Production Company – International (“Claimant”), we hereby give notice of Claimant’s challenge to Ecuador’s appointment of Prof. Brigitte Stern as the second arbitrator in this arbitration.

Claimant received Respondent’s notice of Prof. Stern’s appointment as arbitrator on November 14, 2011. Pursuant to Article 11 of the UNCITRAL Arbitration Rules, Claimant hereby challenges Prof. Stern based on relevant circumstances that give rise to justifiable doubts as to Prof. Stern’s impartiality or independence to sit as a member of the tribunal in the abovereferenced matter.

As stated in Article 10 of the UNCITRAL Arbitration Rules, “[a]ny arbitrator may be challenged if circumstances exist that give rise to justifiable doubts as to the arbitrator’s impartiality or independence.” Claimant maintains that that is the case here. Indeed, because Prof. Stern (1) has already prejudged key issues that constitute the very subject-matter of this dispute, (2) has further failed to accept her appointment and disclose relevant facts and circumstances, and (3) has a consistent record of appointments by Respondent States that justifiably give rise to doubts regarding her impartiality and independence, Claimant hereby request that Respondent agree to her challenge or that Prof. Stern refuse to accept her appointment (or that she withdraw if acceptance ensues).