(i) the specific relief sought;
(ii) the material facts and circumstances on which the Claimant relies; and
(iii) a preliminary statement of the evidence on which the Claimant intends to rely.

(2) The Respondent shall, within the period of time determined by the Arbitral Tribunal, submit a Statement of Defence, which, unless previously provided in the case, shall include;

(i) a statement as to whether and to what extent the Respondent accepts or denies the relief sought by the Claimant;
(ii) the material facts and circumstances on which the Respondent relies;
(iii) any counterclaim or set-off claim and the grounds on which it is based; and
(iv) a preliminary statement of the evidence on which the Respondent intends to rely.

(3) The Arbitral Tribunal may determine that the parties are to submit additional written statements.

Article 22 Amendments to Claim or Defence