Extract to table

2 set a deadline of March 24, 2023 for the simultaneous exchange of document production requests, and provided that objections to such requests shall be submitted no later than April 7, 2023, unless the Parties agree otherwise or a Party elects to submit objections together with its initial requests

3, that document production requests shall be governed by the principles set forth in Articles 3 and 9 of the IBA Rules, adapted as the Tribunal deems appropriate

Those principles, which are now well established in international arbitration practice, require that document production requests satisfy the following criteria: (a) Specificity: Each request must identify, with reasonable particularity, a narrow and specific category of documents, rather than broad, undefined classes of documents

(b) Relevance and Materiality: Requested documents must be relevant to the case and material to its outcome

The requesting party bears the burden of demonstrating that the documents sought are relevant to specific issues that the Tribunal must determine

(c) Proportionality: The burden of producing the requested documents must be proportionate to the significance of the documents to the issues in dispute