ARB/19/28, Procedural Order No. Using as evidence of document production of which was refused on notice 165. 11: Failure to do so will inevitably cause slippage in the calendar and may make it necessary to postpone the hearing.. 16-21, Philip Morris Asia Limited v. Commonwealth of Australia, PCA Case No. ARB/12/14 and 12/40, Procedural Order No. ARB/05/22, Procedural Order No. 2. ARB/16/9, Procedural Order No. 11, Standard Chartered Bank (Hong Kong) Limited v. United Republic of Tanzania II, ICSID Case No. 35, 2011, p. 83. ARB(AF)/12/1, Procedural Order on Privileged Document Production, 5 July 2013, para. 4 Decision on the Claimant Objections to the Respondent Claims of Privilege, 3 November 2018, para. 2009-04, Procedural Order No. v. Republic of Peru ICSID Case No. Queen Mary Survey, International Arbitration Survey: Current and Preferred Practices in the Arbitral Process Survey Findings, 2012, p. 25. 1, 18 Mar 2021, para. Glamis Gold Ltd. v. United States of America, Decision on Objections to Document Production, 20 July 2005, para. 10, South American Silver Limited (Bermuda) v. The Plurinational State of Bolivia, PCA Case No. 29-30. 2017); Sandles v. Magna Legal Services, LLC Civil Court, City of New York N.Y.S.3d 843 (2018). Table of Contents Introduction Discovery - Order 11 Nature and scope Interrogatories Objective Procedure Who may administer interrogatories? 3.5; Philip Morris Asia Limited v. Commonwealth of Australia, PCA Case No. ARB(AF)/00/1, Award, 9 January 2003, paras. PDF EVIDENCE ACT - placng.org - Under the Bankers' Books Evidence Act, 1891, certified copies can be produced, instead of the original entries in the books of Banks in certain circumstances. 3, 2010, pp. 6; IBA Rules, Article 3(3)(b);1999 IBA Working Party & 2010 IBA Rules of Evidence Review Subcommittee, Commentary on the revised text of the 2010 IBA Rules on the Taking of Evidence in International Arbitration, pp. 44-46. 5; Fraport AG Frankfurt Airport Services Worldwide v. The Republic of the Philippines, ICSID Case No. and Antin Energia Termosolar B.V.) v. Kingdom of Spain, ICSID Case No. 4 on the Production of Documents Referred to in the Parties' Privilege Logs, 03 May 2021, paras. Nigel, B., Partasides, C. et al., Chapter 6. 11; Standard Chartered Bank (Hong Kong) Limited v. United Republic of Tanzania II, ICSID Case No. Power Group, L.C. Document produced in answer to notice to be given as evidence if . 6b on the Claimant Disclosure Obligations, 15 January 2018, para. B. 9.2, Nord Stream 2 AG v. European Union PCA Case No. ICC Commission Report: Decision on Costs in International Arbitration, ICC Dispute Resolution Bulletin, 2015, Issue 2. 11-14, British Caribbean Bank Limited v. The Government of Belize, PCA Case No. 5, 19 March 2013, para. ARB/77/1, Excerpts of Award, 30 November 1979, para. 4 Decision on the Claimant Objections to the Respondent Claims of Privilege, 3 November 2018, para. 35, 2011, p. 94: The procedural rules or special instructions of the arbitral tribunal, issued upon a request of the parties, define whether there will be a second round of exchange of submissions between the parties on document production requests. 2012-17, Award, 24 March 2016, para. 16.2, Churchill Mining PLC and Planet Mining Pty Ltd v. Republic of Indonesia, ICSID Case No. The IBA Rules, 29 May 2010, p. 4;The IBA Rules, 17 December 2020, p. 3 with commentaries. ARB/16/16, Procedural Order No. 16;B-Mex, LLC Deana Anthone, Neil Ayervais, Douglas Black and others v. United Mexican States ICSID Case No. ARB/10/11 and ARB/10/18, Decision on the Corruption Claim, 25 February 2019, paras. 28; Biwater Gauff (Tanzania) Ltd. v. United Republic of Tanzania, ICSID Case No. (i) of the sovereign authority - An example for this would be Legislations that are made by both the Parliament and State Legislature. 7; ACP Axos Capital GmbH v. Republic of Kosovo, ICSID Case No. ARB/05/17, Award, 6 February 2008, AGIP S.p.A. v. People's Republic of the Congo, ICSID Case No. Statements, etc., in maps, charts and plans. Reliance on Copies in the Absence of Original Documents Churchill Mining PLC and Planet Mining Pty Ltd v. Republic of Indonesia, ICSID Case No. ARB(AF)/00/1, Award, 9 January 2003, paras. Document production in proceedings including mass claims can be lengthy. The IBA Rules, 29 May 2010, Art. 14. Hanotiau, B., Document Production in International Arbitration: A Tentative Definition of 'Best Practices', ICC Special Supplement, 2006, para. 16, Churchill Mining PLC and Planet Mining Pty Ltd v. Republic of Indonesia, ICSID Case No. 101-102, Nova Group Investments, B.V. v. Romania, ICSID Case No. 5.4, AES Summit Generation Limited and AES-Tisza Erm Kft. ARB/16/16, Procedural Order No. 171. The substance of a document can be demonstrated by Primary or auxiliary evidence. 72. Reisman, W.M., Crawford, J.R. and Bishop, D.R., Chapter 12: Procedure and Proof: Developing the Case, in Foreign Investment Disputes: Cases, Materials and Commentary, 2nd ed., Kluwer Law International, 2014, pp. ARB/12/10, Decision on Saint Lucia's Request for Suspension or Discontinuation of Proceedings, 8 April 2015, para. Although document production can occur at any time,26 parties usually agree at the beginning of the arbitration on a procedure for document production.27 In practice, the requests are often28scheduled for after the exchange of the statement of claim and the statement of defence.29. Reed, L.F. and Hancock, G., Chapter 7. 7 Concerning the Claimants Request for Provisional Measures, 29 March 2017, para. 4. 10;Sabharwal, D. and Zaman, R., Vive la difference? The Production of Documents in International Arbitration - Semantic Scholar 1-6;The Prague Rules, 2018, Article 4.3-4.4. Section 9-11-124 - Form of motion for production of documents under These can include generally-applicable testimonial privileges or rules of confidentiality (such as attorney-client privileges, doctor patient privileges, or state secrets), as well as the admissibility of settlement communications and communications between counsel.. ARB/15/22, Procedural Order No. ARB/13/31, Decision on Annulment, 30 July 2021, para. PART VI - STATEMENTS UNDER SPECIAL CIRCUMSTANCES 37. 2009-04, Procedural Order No. ARB/05/22, Procedural Order No. It has even been described as a general principle of law.. 4.6, Latam Hydro LLC and CH Mamacocha S.R.L. ICSID, Production of Documents ICSID Convention Arbitration; ICSID Secretariat, Proposals for the Amendment of the ICSID Rules, Vol. ARB/19/28, Procedural Order No. ARB/08/12, Procedural Order No. 4, 23 February 2015, para. 7 on Document Production, 21 July 2015, para. v. Canada, ICSID Case No. Tenaris S.A. and Talta - Trading e Marketing Sociedade Unipessoal Lda. 3, 2010, pp. 17, 04 September 2020, para. VI. ICSID Secretariat, Proposals for the Amendment of the ICSID Rules, Volume III, 2 August 2018, para. ARB/05/22, Procedural Order No. 2, 24 May 2006, p. 7, Latam Hydro LLC and CH Mamacocha S.R.L. (eds. 101-102. UNCT/15/2, Final Award, 21 November 2022, para. ARB/21/16, Procedural Order No. 72, Capital Financial Holdings Luxembourg S.A. v. Republic of Cameroon, ICSID Case No. ARB(AF)/12/1, Procedural Order on Privileged Document Production, 5 July 2013, para. The IBA Rules, 29 May 2010, Art. Discovery is a formal process used in the United States by which adverse parties in litigation exchange information and documents in order to identify the evidence by which they will prove their case at trial.7 Discovery occurs at the outset of a case and is much larger than document production because, on top of exchanges of documents, it also includes depositions, interrogatories and requests for admissions.8 Disclosure in English law is a similar procedure by which a party must disclose, first through a list, all documents that have a bearing on the case even if they are harmful to it.9, Although similar, document production in international arbitration differs from discovery and disclosure. Waincymer, J.M., Chapter 11: Documentary Evidence, Procedure and Evidence, in International Arbitration, 2012, p. 880. ARB/19/6, Procedural Order No. 4, Biwater Gauff (Tanzania) Limited v. United Republic of Tanzania, ICSID Case No. 3, 4 October 2001, para. 22;Latam Hydro LLC and CH Mamacocha S.R.L. It's one big criminal cover up after another. 4 (Interim Measures), 27 February 2020, paras. ARB(AF)/12/1, Procedural Order on Privileged Document Production, 5 July 2013, para. 9, Helnan International Hotels A/S v. Arab Republic of Egypt, ICSID Case No. TAPIWA MAKORE MURDER: COURT HANDS DOWN SENTENCE | 12 JULY 2023 | sentence 1999 IBA Working Party & 2010 IBA Rules of Evidence Review Subcommittee, Commentary on the IBA Rules on the Taking of Evidence in International Arbitration, 2010, The work product doctrine (also called the litigation privilege). 15: The importance of the burden of proof in determining whether or not a request should be granted is often underestimated.. In order for documentary evidence to be admitted at trial it must berelevantpursuant toFRE 402and403. The RTI Act, though allows certified copy, it does not permit the same " to be given in evidence ". 45, ACP Axos Capital GmbH v. Republic of Kosovo, ICSID Case No. Hanotiau, B., Document Production in International Arbitration: A Tentative Definition of 'Best Practices', ICC Special Supplement, 2006. 2010-17, Award on Costs, 20 August 2014, para. See:Swerdloff, N., Elul, H.M. et al., Arbitrators Power to Sanction Non-Compliance in Discovery in International Commercial Arbitration, in Van den Berg, A. J. Schreueur, C., The ICSID Convention: A commentary, Cambridge University Press, 2009. 1, 18 Mar 2021, para. 2, 6 March 2017, p. 2, William Ralph Clayton and others v. Government of Canada, PCA Case No. V. Pillai of 5th year pursuing B.A. 207-210, Vctor Pey Casado and President Allende Foundation v. Republic of Chile I, ICSID Case No. 22, 26, Biwater Gauff (Tanzania) Limited v. United Republic of Tanzania, ICSID Case No. 31, Issue 6, 2014, pp. ARB/06/5, Decision on Provisional Measures, 6 April 2007, paras. 340-346. Biwater Gauff (Tanzania) Limited v. United Republic of Tanzania, ICSID Case No. 43. 1 (Procedural Timetable and Conduct of the Arbitration), 14 Oct 2020, para. 131, 132 Evidence Act |Production of documents or electronic records ARB/05/19, Decision on Jurisdiction, 17 October 2006, para. 549-572. 13, 11 July 2012, paras. 72-73, 77. 7 on Document Production, 21 July 2015; FREIF Eurowind Holdings Ltd v. Kingdom of Spain, SCC Case No. Sandles v. Magna Legal Services, LLC Civil Court, City of New York N.Y.S.3d 843 (2018). Documentary evidence is any evidence that is, or can be, introduced at a trial in the form of documents, as distinguished from oral testimony. ICC Arbitration Commission Report on Managing E-Document Production, 2016. In investment arbitration, only the ICSID Rules specifically refer to adverse inferences.88The IBA Rules89and now, the Prague Rules90explicitly allow arbitral tribunals to draw adverse inferences. Parties often use a Redfern Schedule to exchange document requests.36 This schedule usually has five columns.37. ARB/07/27, Decision on Annulment, 9 March 2017, para. Watch Karen Davila's interviews with government officials and analysts on #ANCHeadstart (13 July 2023) | government, interview, ABS-CBN News Channel and Energia Termosolar B.V. (formerly Antin Infrastructure Services Luxembourg S..r.l. Document production can be sought in a request for provisional measures.30 The requesting party must prove that such documents could be lost or jeopardized without the provisional measure31as well as prove that the usual criteria for provisional measures are met.32However, ordering document production pursuant to Article 47 of the ICSID Convention remains exceptional.33Tribunals considered that preserving relevant documents for the proceedings is part of parties general duty of good faith.34. Supreme Court on the admissibility of electronic evidence under Section Biwater Gauff (Tanzania) Ltd. v. United Republic of Tanzania, ICSID Case No. 10 - Annex I, 26 Feb 2021, Patel Engineering Limited v. The Republic of Mozambique PCA Case No. 8-9, Caratube International Oil Company LLP v. The Republic of Kazakhstan, ICSID Case No. 2366-2368. 132. 8; South American Silver Limited v. Bolivia, PCA Case No. UNCT/02/1, Tribunal Decision Relating to Canadas Claim of Cabinet Privilege, 8 October 2004, para. This article deals with the various provisions related to public documents and presumption as to documents under the Indian Evidence Act. ARB/15/18, paras. 217, Waste Management, Inc. v. United Mexican States (II), ICSID Case No. 35219-2), 30 March 1983, para. Tribunals and/or parties often refer to the IBA rules, The Prague Rules: Arbitral Efficiency under the Lens, , ICC Dispute Resolution Bulletin, Issue 2, 2019, p, Whilst this inquisitorial approach will be familiar and welcome to users of, arbitration from civil law jurisdictions, it may come as somewhat of a culture shock, to some common law practitioners who have trained and practiced in jurisdictions. 30; Europe Cement Investment & Trade S.A. v. Republic of Turkey, ICSID Case No. Public Documents and Presumption as to Documents under the Indian Apotex Holdings Inc. and Apotex Inc. v. United States of America, ICSID Case No. ARB/15/22, Procedural Order No. Sabharwal, D. and Zaman, R., Vive la difference? AGIP S.p.A. v. People's Republic of the Congo, ICSID Case No. It is explained by the fact that in order for a party to ascertain whether certain documents are necessary to successfully argue its case or meet the burden of proof lying upon it, it is first necessary to present its own case and know the position of the other party. Adem Dogan v. Turkmenistan, ICSID Case No. 2, 6 March 2017, para. ARB/21/63, Procedural Order No. UNCT/15/3, Procedural Order No. 132, Azurix Corp. v. the Argentine Republic, ICSID Case No. UNCT/07/1, Decision of the Tribunal on Production of Documents, paras. Tercier, P. and Bersheda, T., Document Production in Arbitration: A Civil Law Viewpoint, The Search for Truth in Arbitration, ASA Special Series No. 15. v. Canada, ICSID Case No. 3, 5 July 2017, para. ARB(AF)/16/3, Procedural Order No. Secondary Evidence. 27-29. 2347-2348. Discovery (law) - Wikipedia 12, Amec Foster Wheeler USA Corporation, Process Consultants, Inc., and Joint Venture Foster Wheeler USA Corporation and Process Consultants, Inc. v. Republic of Colombia ICSID Case No. Hanotiau, B., Document Production in International Arbitration: A Tentative Definition of 'Best Practices, ICC Special Supplement, 2006, para. Swerdloff, N., Elul, H.M. et al., Arbitrators Power to Sanction Non-Compliance in Discovery in International Commercial Arbitration, in Van den Berg, A. J. ARB/15/31, Procedural Order No. v. Republic of Peru, ICSID Case No. Canfor Corporation and others v. United States of America, Procedural Order No. . ARB/16/25, Procedural Order No. v. Republic of Slovenia, ICSID Case No. v. Republic of Peru, ICSID Case No. ARB/02/3, Decision on Respondents Objections to Jurisdiction, 21 October 2005, para. Grenada Private Power Limited and WRB Enterprises, Inc. v. Grenada, ICSID Case No. 16, 15 Feb 2018, para. ARB/16/16, Procedural Order No. 2012-17, Award, 24 March 2016, para. Derains, Y., Towards Greater Efficiency in Document Production before Arbitral Tribunals - A Continental Viewpoint, ICC Bulletin, Special Supplement 83, 2006. 3.2; South American Silver Limited v. Bolivia, PCA Case No. The arbitral tribunals decision has no impact on the parties burden of proof.60. ARB/12/14 and 12/40, Procedural Order No. 1. ARB/05/19, Decision on Jurisdiction, 17 October 2006, para. ARB/07/27, Decision on Annulment, 9 March 2017, para. ARB/19/28, Procedural Order No. 4, International Bar Association Rules on the Taking of Evidence in International Arbitration with commentaries, 2020, Arts. ARB/19/28, Procedural Order No. 35, 2011, p. 96: The requesting party must make it clear with reasonable particularity what facts/ allegations each document (or category of documents) is intended to establish. 28. 3(3)(c); Churchill Mining PLC and Planet Mining Pty Ltd v. Republic of Indonesia, ICSID Case No. 15.2; ACP Axos Capital GmbH v. Republic of Kosovo, ICSID Case No. Glamis Gold Ltd. v. United States of America, Decision on Objections to Document Production, 20 July 2005, paras. 19. ARB/08/12, Procedural Order No. ICSID Convention Article 43;UNCITRAL Model Law, Article 19(2); United Nations Commission on International Trade Law, Analytical Commentary on the Draft text of the Model Law, 1985, p. 46; ICSID Arbitration Rules Article 34(2); ICSID Arbitration Rules (2022), Article 36(3);ICSID Additional Facilities Arbitration Rules Article 41(2); ICSID Additional Facilities Arbitration Rules (2022), Article 46(3);UNCITRAL Arbitration Rules, 2013, Article 27(3);SIAC Investment Rules, 2017, Article 24(f);Phoenix Action Ltd v. Czech Republic, ICSID Case No. UNCT/15/3, Procedural Order No. Apotex Holdings Inc. and Apotex Inc. v. United States of America, ICSID Case No. 13, 11 July 2012, para. 29, 31, Biwater Gauff (Tanzania) Ltd. v. United Republic of Tanzania, ICSID Case No. ARB/98/2, Decision on the Application for Annulment of the Republic of Chile, 18 December 2012, para. 2018-39, Procedural Order No. Production of documents under evidence act - Legalbonanza Biwater Gauff (Tanzania) Ltd. v. United Republic of Tanzania, ICSID Case No. Both parties (claimant and respondent) are free to request the production of documents. Political and institutional sensitivity, In case of political or institutional sensitivity, tribunals have requested very specific requests from States78and a showing that States performed a balancing test between the sensitivity of the requested information and its value for the requesting partys case.79Requests of document production were also rejected where they were important to ongoing criminal proceedings.80. Exclude grammatical variations of your search terms. 45, Theodoros Adamakopoulos, Ilektra Adamantidou, Vasileios Adamopoulos and others v. Republic of Cyprus, ICSID Case No. As a matter of principle, a request for document production should be submitted no earlier than and no later than after the first exchange of the parties submissions on the merits. 1. 319; Flemingo DutyFree Shop Private Limited v. Republic of Poland, Award, 12 August 2016, para. 3, 5 April 2016, paras. 2013-15, Procedural Order No. 11, Issue 4, 2014, p. 8. 2362-2363. ARB/15/41, Procedural Order No. 10. ARB/19/28, Procedural Order No. ARB/05/22, Procedural Order No. William Ralph Clayton and others v. Government of Canada, PCA Case No. 11-16; Tennant Energy, LLC v. Government of Canada, PCA Case No. . 33, 46. See the new 2020 IBA Rules: The IBA Rules, 29 May 2010, Arts. 11, Issue 4, August 2014. 11. Notice to Produce Documents in Civil Cases - Saji Koduvath Associates ARB/19/28, Procedural Order No. 2010-18, Decisions on Respondent Requests for Document Production, 19 December 2013; Lao Holdings N.V. v. Lao People's Democratic Republic, ICSID Case No. ARB/06/5, Decision on Provisional Measures, 6 April 2007, para. ARB/19/34, Procedural Order No. 1-30, pp. 2009-04, Procedural Order No. 2, 2017. ), Written Evidence and Discovery in International Arbitration: New Issues and Tendencies, Dossiers of the ICC Institute of World Business Law, Vol. Power of the judge. 11 on Further Document Production, 9 July 2019, Italba Corporation v. Oriental Republic of Uruguay, ICSID Case No. 18; Latam Hydro LLC and CH Mamacocha S.R.L. ARB/16/19, Procedural Order No. ARB/05/22, Procedural Order No. (as . Too much time is wasted in courts in . Van Houtte, V., Adverse Inferences in International Arbitration, Dossier of the ICC Institute of World Business Law: Written Evidence and Discovery in International Arbitration: New Issues and Tendencies, 2009, pp. 2343-2344: scope and procedures for disclosure as between the parties in an international arbitration depend on the parties agreement to arbitrate and, absent such an agreement, the arbitrators exercise of their discretion, largely unconstrained by national law limitations.. Jencks material is evidence that is used in the course of a federal criminal . and Energia Termosolar B.V. (formerly Antin Infrastructure Services Luxembourg S..r.l. 37. 62, Latam Hydro LLC and CH Mamacocha S.R.L. 7. 6; Global Telecom Holding S.A.E. ARB/12/14 and 12/40, Procedural Order No 14, 22 December 2014, para. Document Production - Jus Mundi Secondary Evidence is the document which is not original document but those . Sanctions for non-compliance with the tribunals order for document production, Arbitral tribunals do not have the same powers as domestic courts in the context of document production.86However, tribunals can draw adverse inferences against parties who fail to comply with a document production order. Born, G.B., Chapter 16: Disclosure in International Arbitration, in International Commercial Arbitration, Kluwer Law International, 2014, pp. 2 Decision on Bifurcation, 21 February 2018, paras. ARB/13/31, Decision on Annulment, 30 July 2021, para. 4, 2003, p. 1325. 6-7. 132; Azurix Corp. v. the Argentine Republic, ICSID Case No. 5, 9.2, International Bar Association Rules on the Taking of Evidence in International Arbitration with commentaries, 2020, Art. 3(3)(c), Churchill Mining PLC and Planet Mining Pty Ltd v. Republic of Indonesia, ICSID Case No. IBA Arbitration Guidelines and Rules Subcommittee, Report on the reception of the IBA arbitration soft law products, September 2016. 14-15, United Parcel Services of America Inc. (UPS) v. Canada(UNCITRAL), Decision of the Tribunal relating to Canada's Claim of Cabinet Privilege, October 8, 2004, para. 3, 2010. 102; Caratube International Oil Company LLP and Devincci Salah Hourani v. Republic of Kazakhstan (II), ICSID Case No. 2017). Producing Documents, Electronically Stored Information, and Tangible Things, or Entering onto Land, for Inspection and Other Purposes | Federal Rules of Civil Procedure | US Law | LII / Legal Information Institute LII Federal Rules of Civil Procedure Rule 34. 2, 6 March 2017, para. ARB (AF)/00/1, Procedural Order No. THE USE OF DOCUMENTS IN CROSS-EXAMINATION ARB(AF)/08/1, Order of the Tribunal Taking Note of the Discontinuance of the Proceedings and Allocation of Costs, 27 October 2010, para. ARB/21/16, Procedural Order No. Sign in. The production of documents in investment arbitration is also hindered by complex corporates structures because relevant documents would be out of reach for the tribunal81or if States have control over the investors documents in the context of criminal investigations or bankruptcy proceedings.82. 43, Mesa Power Group LLC v. Government of Canada, PCA Case No. 9(2)(e), Pope & Talbot v. Government of Canada, Decision on Official Secrecy and Professional Privilege, 6 September 2000, paras. 43, 52-53. 14, 24 June 2020, para. 35; Phoenix Action Ltd v. Czech Republic, ICSID Case No. Section 90 of the Evidence Act reads as under: "90. 13, 11 July 2012, paras. v. Canada, ICSID Case No. A different procedure from discovery and disclosure. 34-38, Latam Hydro LLC and CH Mamacocha S.R.L. The validity of any such objection shall be decided on by the Court. 253-254, Glamis Gold Ltd. v. United States of America, Award, 8 June 2009, paras. ICSID Arbitration Rules (2022), Article 36-37, , PCA Case No. 198, Venezuela Holdings B.V. and others (formerly Mobil Corporation and others) v. Bolivarian Republic of Venezuela, ICSID Case No. If sometime later, Ron wants to use that document as evidence, he will not be able to do so without Harry's consent. It further characterizes the narrative evidence in Primary and auxiliary evidence. and Owens-Illinois de Venezuela, C.A. ARB/13/31, Decision on Annulment, 30 July 2021, para. We continuously identify new themes to add to the existing Wiki Notes as well as Contributors to author new Notes. 35, Issue 1, pp. v. Republic of Peru ICSID Case No. Application of this Part. 5, 28 May 2004, paras. Railroad Development Corporation v. Republic of Guatemala, Decision on Provisional Measures, ICSID Case No. ARB/17/13, Decision on Provisional Measures, 26 September 2018, paras. 10, para. 5, 19 March 2013, para. 22, 25-26, Elliott Associates, L.P. v. Republic of Korea, PCA Case No. The HTML version of this document remains fully available on our website. Tercier, P. and Bersheda, T, Document Production in Arbitration: A Civil Law Viewpoint, The Search for Truth in Arbitration, ASA Special Series No.
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