Request and Statement of Claim (HEAP Track, Memorial) (ICC Rules) by OLL
REQUEST AND STATEMENT OF CLAIM
ICC Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE ICC RULES OF ARBITRATION (2026) (HIGHLY EXPEDITED ARBITRATION — APPENDIX VI)
BETWEEN
[Claimant's name]
[Claimant's address]
("Claimant")
— and —
[Respondent's name]
[Respondent's address]
("Respondent")
Submitted on behalf of the Claimant by: [Representative's title and name]
Date: [date]
This template numbers every paragraph, including optional ones, as though included. Delete any paragraph or clause that does not apply to this filing and renumber sequentially before submission.
Preliminary Notes
"HEAP" is ICC's own shorthand for the Highly Expedited Arbitration Provisions (Appendix VI), also referred to as "Highly Expedited Arbitration" in Article 33 of the main Rules.
Availability. HEAP is opt-in only, with no monetary threshold restricting its application — unlike the Expedited Procedure's default-application threshold under the Standard track (see Appendix V). Under HEAP, the Tribunal is a sole arbitrator, the award is due within 3 months of the initial CMC, the Tribunal may refuse document production requests entirely, and the Tribunal may decide the case on the documents alone, without an oral hearing.
Merged Filing. This single document constitutes both the Request for Arbitration and the Statement of Claim, filed together as one filing event. There is no separate, later-filed Statement of Claim under this track. Because Appendix VI requires the full legal and factual basis — and, to the extent possible, the evidence relied on — to be filed with the Request, this document is necessarily drafted in full-argument form; there is no abbreviated facts-only variant under HEAP.
Confirm the Parties have opted into Highly Expedited Arbitration pursuant to Appendix VI/Article 33 before using this template — HEAP is never the default track.
Introduction
This Request and Statement of Claim is submitted together, pursuant to Appendix VI/Article 33, given the Parties' opt-in to HEAP.
This document includes the full legal and factual basis and, to the extent possible, the evidence relied on — not a bare Request.
Section index: (I) the Parties; (II) Jurisdiction and HEAP Eligibility; (III) Factual Background; (IV) Legal Grounds; (V) Loss and Quantum; (VI) Relief Sought; (VII) Evidence Relied On; (VIII) Exhibit Schedule.
The Parties
The Claimant is [Claimant's name], [description].
The Respondent is [Respondent's name], [description].
Jurisdiction and HEAP Eligibility
The Tribunal has jurisdiction pursuant to the arbitration agreement at [clause reference], seated at [seat of arbitration].
HEAP eligibility is confirmed: there is no monetary threshold restricting opt-in, and the Parties have elected sole-arbitrator determination with a 3-month award deadline from the initial CMC.
Counterclaims under HEAP. Appendix VI, Article 2(5)-(8) ("Request and Statement of Claim; Answer and Statement of Defence; Counterclaim; and Reply to Counterclaim") gives HEAP its own counterclaim mechanism. If the Respondent submits a Statement of Counterclaim with its Answer and Statement of Defence (Article 2(5)), the Claimant must submit a Reply to Counterclaim within 20 days of receipt (Article 2(7)-(8)) — a separate filing, not generated here since no counterclaim exists yet at the time this Request and Statement of Claim is filed.
Factual Background
Chronology. [Insert.]
Dramatis Personae. [Insert.]
Contractual Matrix. [Insert.]
Narrative. [Insert, cross-referenced to exhibits.]
Legal Grounds
Cause of Action 1. [State the legal basis, with authorities.]
Cause of Action 2. [If applicable.]
Loss, Damage and Quantum
Loss and damage in the amount of [amount], particularised as follows: [quantum breakdown].
Interest claimed at [interest rate] from [date].
Relief Sought
The Claimant respectfully requests that the sole arbitrator: (a) DECLARE that [declaratory relief sought]; (b) ORDER the Respondent to pay [amount]; (c) AWARD interest as pleaded above; (d) ORDER the Respondent to pay the costs of this arbitration; and (e) ISSUE an award within 3 months of the initial CMC, per the HEAP award deadline.
Evidence Relied On
Evidence relied on is included to the extent possible at this stage, not deferred — document production may be refused entirely by the Tribunal under HEAP, and the Tribunal may decide the matter on documents alone. [List/summarise the evidence relied on and attach in full where possible.]
Exhibit Schedule
Exhibit No. | Description | Referenced at ¶ |
C-1 | [Document] | ¶ [ ] |
Respectfully submitted,
[Representative's title and name]
On behalf of the Claimant
Date: [date]
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