LCIA Statement of Reply to Defence to Counterclaim (Pleading)
The Claimant's reply to the Statement of Defence under Art. 15.4, due 28 days from receipt of the Statement of Defence (or the Respondent's election under Art. 15.3(i)). This is the pleading form — bare material facts addressing new matters raised in the Defence, and, where the Respondent raised a Counterclaim, a bare-facts Defence to Counterclaim only. Use where the Tribunal directs a facts-first approach or counsel prefers to defer legal argument.
STATEMENT OF REPLY TO THE DEFENCE TO COUNTERCLAIM
[This template applies only where: (1) the Respondent has pleaded a Counterclaim in its Statement of Defence under Art. 15.3; and (2) the Claimant's Statement of Reply included a Statement of Defence to Counterclaim under Art. 15.4. This document is filed by the Respondent, as Counterclaim-Claimant.]
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 Respondent/Counterclaim-Claimant by: [Representative's title and name]
Date: [date]
Introduction
This Statement of Reply to the Defence to Counterclaim is submitted pursuant to Art. 15.5 of the LCIA Arbitration Rules (2020), pleading material facts only in response to new matters raised in the Claimant's Defence to Counterclaim, within 28 days of the Respondent's receipt of the Claimant's Statement of Reply.
Save as the Tribunal may otherwise direct, this document is the last written statement to be filed in the arbitration, pursuant to Art. 15.6 of the LCIA Rules.
Reply to the Defence to Counterclaim
(Material Facts Only)
[Bare facts addressing new matters raised in the Defence to Counterclaim — no argument.]
[Bare response to any affirmative defences or set-off pleaded by the Claimant against the Counterclaim.]
Relief Sought:
The Respondent/Counterclaim-Claimant maintains its request for:
[counterclaim quantum amount] on the Counterclaim;
interest as pleaded in the Statement of Defence/Counterclaim;
costs of the Counterclaim; and
further or other relief.
Annexure Schedule
All documents relied upon by the Respondent/Counterclaim-Claimant accompany this Statement of Reply to the Defence to Counterclaim, in accordance with Art. 15.5, as follows:
Exhibit No. | Description | Referenced at ¶ |
Respectfully submitted,
[Representative's title and name]
On behalf of the Respondent/Counterclaim-Claimant
Date: [date]
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