I. THE PARTIES’ REQUESTS AND PROPOSALS

1. The Respondent requests that the Tribunal exercise its discretion under Articles 17 and 23(3) of the UNCITRAL Rules to order that its objections to jurisdiction be heard in a preliminary phase of the proceedings.1 The Respondent proposes three possible timetables.2 Under the Respondent’s preferred option, the Claimant would initially lodge a limited Statement of Claim addressing only issues of jurisdiction or admissibility within 90 days of a procedural order on bifurcation by the Tribunal. Alternatively, the limited Statement of Claim could contain the Claimant’s full legal case but limit any evidence to issues of jurisdiction and admissibility.3 This limited Statement of Claim would be followed, within 90 days, by the Respondent’s Statement of Objections to Jurisdiction and Admissibility together with the evidence upon which it wishes to rely. A hearing on jurisdiction and admissibility would be held in 2013.4 The Respondent attached proposed timetables to its submissions.

2. The Claimant requests that the Tribunal refuse to order bifurcation of the proceedings. Alternatively, if the Tribunal is not inclined to refuse bifurcation at this stage, it should determine whether to order bifurcation only after the submission of full memorials by both Parties. The Claimant proposes a detailed timetable leading to an exchange of submissions on the desirability of bifurcation in late 2013.5 The Claimant attached proposed timetables to its submissions.