STATEMENT OF REPLY [AND DEFENCE TO COUNTERCLAIM]
["AND DEFENCE TO COUNTERCLAIM" appears in the title, and Sections 4–7 below apply, only where the Respondent has raised a Counterclaim in its Statement of Defence and this filing also serves as the Claimant's Defence to Counterclaim, pursuant to Art. 15.4.]
LCIA Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE LCIA ARBITRATION RULES (2020)
BETWEEN
[Claimant's name]
[Claimant's address]
("Claimant"["Counterclaim-Respondent"])
— and —
[Respondent's name]
[Respondent's address]
("Respondent"[, "Counterclaim-Claimant"])
Submitted on behalf of the Claimant by: [Representative's title and name]
Date: [date]
Introduction
This Statement of Reply[, and Defence to Counterclaim,] is submitted pursuant to Art. 15.4 of the LCIA Arbitration Rules (2020), within 28 days of the Claimant's receipt of the Respondent's Statement of Defence[/Counterclaim] or of the Respondent's election under Art. 15.3(i).
This Statement of Reply is organised as follows: (I) Reply to the Statement of Defence; [(II) Defence to Counterclaim — General Traverse; (III) Defence to Counterclaim — Paragraph-by-Paragraph Reply; (IV) Defence to Counterclaim — Facts, Legal Grounds, and Affirmative Defences; (V) Quantum Response on the Counterclaim;] (VI) Relief Sought; (VII) Annexure Schedule.
Reply to the Statement of Defence
[Address new factual or legal matters raised in the Statement of Defence that were not already covered by the Statement of Case, with authorities where required.]
Defence to Counterclaim — General Traverse
Include Sections 3–6 only where this filing also serves as the Defence to Counterclaim.
Save as expressly admitted in this document, the Claimant/Counterclaim-Respondent denies each and every allegation made in the Counterclaim as if set out here and traversed individually.
Defence to Counterclaim — Paragraph-by-Paragraph Reply
Counterclaim ¶ | Allegation (summary) | Response |
Defence to Counterclaim —
Facts. [Insert factual narrative in answer to the Counterclaim.]
Legal Grounds. [State the legal basis in answer to the Counterclaim, with authorities.]
Affirmative Defence 1: [basis, if applicable].
Include the following paragraph only where the Claimant/Counterclaim-Respondent pleads a set-off against the Counterclaim: "Set-Off. The Claimant/Counterclaim-Respondent pleads set-off in the amount of [set-off amount] against any sum found due on the Counterclaim. The LCIA Rules do not provide a distinct set-off mechanism; this is accordingly pleaded as an ordinary affirmative defence to the Counterclaim, and is distinct from LCIA's 'cross-claim' concept (a claim by one respondent against another respondent in multi-party proceedings — Art. 2.1(iii))."
Quantum Response on the Counterclaim
The Claimant/Counterclaim-Respondent's position on the pleaded counterclaim quantum of [counterclaim quantum amount]: [admit / dispute in whole or part, with reasons].
Relief Sought
The Claimant respectfully requests that the Tribunal:
give effect to the matters pleaded in this Reply in support of the relief sought in the Statement of Case;
[where a Counterclaim is pleaded] DISMISS the Counterclaim in its entirety, alternatively in part;
[where a set-off is pleaded against the Counterclaim] GIVE EFFECT to the set-off pleaded above in the amount of [set-off amount];
[where a Counterclaim is pleaded] ORDER the Respondent/Counterclaim-Claimant to pay the costs associated with the Counterclaim;
ORDER the Respondent to pay the costs of this arbitration; and
GRANT such further or other relief as the Tribunal considers just.
Annexure Schedule
All documents relied upon by the Claimant accompany this Statement of Reply, in accordance with Art. 15.4, as follows:
Exhibit No. | Description | Referenced at ¶ |
Respectfully submitted,
[Representative's title and name]
On behalf of the Claimant[/Counterclaim-Respondent]
Date: [date]
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