Mr.

Chairman, and may it please the Arbitral Tribunal My name is - a co-agent for Monrova Corporation, the Respondent in this case. And its my honor to appear in front of the Ho Chi Minh City Arbitration Center (HCMIAC) today. With me today are my co-agent Mr/Ms I will speak in the first 7 minutes, addressing our Then my co-agent Mr/Ms , regarding two problems:

will speak in the next 7mins, addressing our .

Firstly, the subjective of the establishment of the JV is to implement, develop and operate the SHP the SHP to do to the best economic efficiency and for the benefit of the people of Zamba. In economics, the term of economic efficiency implies an economic state in which every resource is optimally allocated to serve each person in the best way while minimizing waste and in efficiency. In terms of production, goods or services are produced or made at their lowest possible cost. Thus, lowering the travel fares to make the reasonable one is the rational way to assure the efficiency. In addition, due to Financial Crisis, Zamban people can not afford to pay the high travel fares. This must be realized by the Anderson; furthermore, it must not have the act to show its respect foragainst the purpose and mission of the JV, subject to Article 1, Charter of the JV. In response to Andersons claim that Monrova has infringed Article 32 of the JV agreement, I we think, keeping that high travel fares would decrease the use of the SHP. The act of lowering the travel fares caused the decreasing of the benefit at the time; however, in a long term, it would keep the SHP run normally, or even stimulate the transportation on SHP because the travel fare is at the reasonable price (not as slightly high as according to the analysts before). Thus it is a good solution to maintain the efficiency of SHP and help recovering the economy of Zamba as well. Essentially, the act of Monrova does not adversely affect to the normal business of the JV in general and Anderson in particular. Moreover, it is baseless to claim that Government of Zamba did not consider the benefit of Anderson. In fact, Government of Zamba directed Monrova to vote to pass a resolution of decreasing the travel fares. As proved by my co-agent (above), the act of lowering the travel fares gives ensures the long-term benefit of the JV; in this way, it this measure prevents both Andersons and Monrovas benefit from being worsenedruined. Thus, the direction of Government of Zamba is judicious and Monrovas act of lowering the travel fares under the direction of the Government of Zamba is justifiable. Next, subject to Article 14, Charter of the JV, every resolution that approved by Monrova may be passed in the vote as it holds 51% of the total capital and this resulted in the justification of the act of lowering the travel fares of Monrova. Besides, there is no act of violating any rules of Monrova. Last but not least, Monrova acknowledges the loss that Anderson suffered due to its act, and accepts to compensate Anderson as a support for its contracting party, in accordance with the spirit of the Good faith principle in the contract law. On the other hand, Anderson must consider the interest in the long term, not an immediate one and respect the benefit of Zamban people, subject to Article 1 of Charter of the JV. In light of the above submission, Anderson respectfully requests the Tribunal to declare that:

Monrovas act of voting to lower the travel fares in relation to SHP is justifiable; the resolution which was passed in November 2008 is still effective and the travel fares must be fixed at 75 Zamban Dollars. Monrova accepts to compensate for Andersons losses as a support to its contracting party; but does not admit that the act of voting to lower the travel fares in relation to SHP is unjustifiable.