Spence International Investments, LLC, Bob F. Spence, Joseph M. Holsten, Brenda K. Copher, Ronald E. Copher, Brette E. Berkowitz, Trevor B. Berkowitz, Aaron C. Berkowitz and Glen Gremillion v. The Government of the Republic of Costa Rica, UNCITRAL, Respondent's Reply on Jurisdiction and Rejoinder on Merits (December 22, 2014)
1. In its Counter-Memorial on the Merits and Memorial on Jurisdiction ("Counter-Memorial"), Respondent explained that this case is about a series of measures that the Republic of Costa Rica has taken to protect one of the most endangered species in the world - the leatherback sea turtle, or tortuga baula. Costa Rica's Pacific coast is one of the turtle's main nesting sites. In 1991, Costa Rica created a national park to protect the beaches and the turtle's nests from human encroachment and development, and the State has taken steps since that time to regulate the use of land in and around the Las Baulas National Park ("National Park" or "Park") the protect that environmentally fragile habit. These measures include formal, compensated expropriation of private property located within the Park's boundaries and environmental guidelines to protect the area.