Dear Members of the Tribunal:

We write to inform the Tribunal that the appellate court in Ecuador affirmed the Lago Agrio Judgment on January 3, 2012.1 Within a matter of days, the Secretariat of the appellate court is likely to issue, upon the Plaintiffs’ request, a certification rendering the Judgment enforceable under Ecuadorian law, despite the Tribunal’s interim measures order that the Republic of Ecuador take all measures at its disposal to suspend enforcement of the Judgment.2 Many additional mechanisms remain available to Ecuador to suspend enforcement of the Judgment, including refraining from issuing the above-noted certification.3 Time is now of the essence to ensure that the Republic takes measures to prevent enforcement of the fraudulent Judgment. Claimants therefore request the Tribunal immediately to: (i) convert the order dated February 9, 2011 (the “Interim Measures Order”) into the form of an Interim Award, as the Tribunal contemplated in the Order; and (ii) request that the Republic of Ecuador inform the Tribunal, by this Friday, January 6, 2012, of the steps that it intends to take to comply with the Interim Measures Order and prevent the Lago Agrio Judgment from becoming enforceable.