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Application to file a written submission as an “other person” pursuant to Article 836 and Annex 836.1 of the Peru – Canada FTA
...Pursuant to the instructions of the Tribunal in Procedural Order No.1, the ICSID Rules apply to the present arbitration except where modified by Chapter Eight of the Peru - Canada FTA...These factors are...a) The Applicant’s submission would assist the Tribunal in the determination of a factual or legal issue related to the arbitration by bringing a perspective, particular knowledge or insight that is different from that of the disputing parties...b) The Applicant’s submission would address a matter within the scope of the dispute...c) The Applicant has a significant interest in the arbitration...d) There is a public interest in the subject-matter of arbitration...For the reasons stated herein, the Applicant requests that the Tribunal: (a) grant leave to the Applicant to file a written submission as “other persons” pursuant to Article 836 and Annex 836.1 of the Peru Canada - FTA; and (b) consider the submission…