68. The Parties may amend or supplement their statements, including the list of documents, and deliver counter-claims and defences to counter-claims during the course of the arbitral proceedings, unless the Arbitral Tribunal considers it inappropriate to allow the amendment, supplement or additional pleadings having regard to: a) the delay in making it; and b) any prejudice suffered by the other Parties. 69. The Parties will deliver copies of all amended, supplemented or new documents delivered under Section 68 to all the Parties. Disclosure 70. The Arbitral Tribunal may order a Party to produce, within a specified time, any documents that: a) have not been listed under Section 67; b) the Party has in its care, custody or control; and c) the Arbitral Tribunal considers to be relevant. 71. Each Party will allow the other Party the necessary access at reasonable times to inspect and take copies of all documents that the former Party has listed under Section 67, or that the Arbitral Tribunal has ordered to be produced under Section 70. 72. The Parties will prepare and send to the Arbitral Tribunal an agreed statement of facts within the time specified by the Arbitral Tribunal. 73. Not later than 21 days before a hearing commences, each Party will give the other Party: a) the name and address of any witness and a written summary of the witness's evidence; and b) in the case of an expert witness, a written statement or report prepared by the expert witness. 74. Not later than 15 days before a hearing commences, each Party will give to the other Party and the Arbitral Tribunal an assembly of all documents to be introduced at the hearing. Hearings and Written Proceedings 75. The Arbitral Tribunal must decide whether to hold hearings for the presentation of evidence or for oral argument, or whether the proceedings will be conducted on the basis of documents and other materials. 76. Unless the Parties have agreed that no hearings will be held, the Arbitral Tribunal must hold hearings at an appropriate stage of the proceedings, if so requested by a Party. 77. The Arbitral Tribunal must give the Parties sufficient advance notice of any hearing and of any meeting of the Arbitral Tribunal for the purpose of inspection of documents, goods or other property or viewing any physical location. 195

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