a. a statement in writing in reply indicating whether or not it agrees with the written statement pursuant to paragraph 2a and, if not, its reply as to the nature of the dispute, the issues likely to arise and its contentions in relation to same;

b. all statements of evidence and copies of documents in reply to material served pursuant to paragraph 2b;

c. any expert reports in reply to material served pursuant to paragraph 2c;

d. any objections which it has to the statements of evidence, experts reports, and documents served pursuant to paragraph 2b, detailing the basis of any such objection;

e. its written submissions in reply on the legal and factual issues involved.

4. If a cross claim is made in accordance with paragraph 2, then the cross claimant may reply, in the same manner as set out in paragraph 3, to written material served in respect of such cross claim pursuant to paragraph 3.