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;
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