vis - Timeline

21 March 2017: • Black Beauty contacted Phar Lap asking for an offer of 100 doses of frozen semen from Nijinski III. • Equatoriana's ban on artificial insemination for race horses has been temporarily lifted (first contact between parties)

24 March 2017: • Phar Lap agrees to supply the 100 doses, but says the semen will be provided in several installments + may not be resold Price: USD 99,500 per dose

28 March 2017: BB objects to price, insists on DDP for delivery, contests applicable law and jurisdiction

31 March 2017: PL accepts a delivery DDP for the Contract, PL wants to include a hardship clause, and suggests arbitration for dispute resolution

12 April 2017: • Mr. Antley's note: wanted to clarify arbitration clause (neutral venue + applicable law)

6 May 2017: Contract was signed • Seller: PL - will ship 3 instalments: 20 May 2017 - 25 doses 3 Oct 2017 - 25 doses 23 Jan 2018 - 50 doses • Buyer: BB - will pay in 2 instalments: 18 May 201: USD 5 million 21 Jan 2017: USD 5 million • Seat of arbitration: Danubia

20 May 2017: "Claimant" sent the first shipment of 25 doses

3 Oct 2017: "Claimant" sent the second shipment of 25 doses

Nov 2017: Ian Bouckaert (Mediterraneo's President) announced 25% tariffs on agricultural products from Equatoriana.

19 Dec 2017: Retaliation - Equatoriana imposes a tariff of 30% upon all agricultural goods from Mediterraneo

20 Jan 2018: PL emails BB to negotiate a price adjustment

21 Jan 2018: Mr. Shoemaker (BB) calls Napravnik (PL) He said a solution would be found and urged PL to authorize the final shipment. Shoemaker said he had no authority to agree on an adpation + never committed to one

10 April 2017: BB drafts the dispute resolution clause (seat and law of arbitration is Equatoriana)

11 April 2017: PL suggests Danubia to be the place of arbitration + law applicable to the sales agreement remains Meditarraneo

12 April 2017: • Ms. Napravnik (PL) and Mr. Antley (BB) severely injured in a car accident

31 July 2018: PL submits Notice of Arbitration PL nominates Wantha Davis as its arbitrator

15 June 2018: Witness Statement of Julie Napravnik

31 July 2018: HKIAC notes the Claimant (PL) has commenced this arbitration, confirms receipt of Claimant's payment of registration fee, invites Davis to sign "Declaration of Acceptance..." and invites respondent to nominate a co-arbitrator, and establishes initial deposits at US$ 25,560 and US$ 10,673 to be transferred by 14 Aug 2018

1 Aug 2018: Ms. Davis signs "Declaration of Acceptance..." (hourly rate US$ 380)

2 Aug 2018: Langweiler (PL) agrees to Davis' hourly rate, declares that has paid the initial deposits, agrees to communicate with HKIAC via email only

24 Aug 2018: Fasttrack (BB): BB has paid inital deposits, agrees to tribunal fees, agrees to communicate with HKIAC via email only, nominates Ms. Dettorie as its arbitrator + Answer to the Notice of Arbitration

23 Aug 2018: Witness Statement of Julian Krone

22 Aug 2018: Witness Statement of Shoemaker

24 Aug 2018: HKIAC acknowledges receipt of Respondent's (BB) Answer, Dr. Dettorie signs "Declaration..." , acknowledges payment of initial fees

28 Aug 2018: HKIAC invites parties to designate a third and presiding arbitrator by 27 Sep 2018

14 Sep 2018: Prof Calvin de Sousa is designated as Presiding Arbitrator

17 Sep 2018: Parties agree with Prof de Souza's hourly rate

18 Sep 2018: HKIAC: arbitral tribunal has now been constituted

2 Oct 2018: PL emails the arbitrators about an arbitration between BB vs. one of its customers (In that arbitration, BB wants adaptation of price)

3 Oct 2018: BB rejects PL's claim of contradictory behavior, says it was taken out of context + says the other arb is confidential

5 Oct 2018: Procedural Order No 1

After the call: Napravnik authorized delivery of 3rd shipment

12 Feb 2018: PL confronted BB's CEO (Ms. Kayla Espinoza) after discovering their breach of the resale prohibition. Espinoza got angry and said she no longer wanted to cooperate with PL