Document production in international arbitration—a practical guide
Produced in partnership with Courtney Lotfi of Dentons
Document production in international arbitration—a practical guide

The following Arbitration practice note produced in partnership with Courtney Lotfi of Dentons provides comprehensive and up to date legal information covering:

  • Document production in international arbitration—a practical guide
  • What is document production in international arbitration?
  • What form does document production take in international arbitration?
  • How are documents produced in international arbitration?
  • Step 1: Make a plan, get organised
  • Step 2: The first written submissions
  • Step 3: Setting the ground rules with procedural orders
  • Step 4: Requests for production
  • Step 5: Production of documents in response to requests for production
  • Step 6: Submission of produced documents as evidence
  • More...

Document production in international arbitration—a practical guide

This Practice Note provides practical guidance on document production in international arbitration proceedings. It addresses the two main forms of document production that arise in international arbitration:

  1. the production of documents in response to a request for production (or request(s) to produce), and

  2. the voluntary production of documents associated with the parties’ written submissions, including their pleadings ((statements of case), witness statements and/or expert reports)

Since each arbitration is different, practitioners should consider any particular features of their case that may have a bearing on document production.

Reference is made throughout this Practice Note to soft law and arbitration rules which may inform or illustrate the process of document production as it takes place in many arbitrations, with particular focus on the IBA Rules on the Taking of Evidence in International Arbitration (the IBA Rules). It reflects the recent version of the IBA Rules, which were promulgated in December 2020.

The following related Practice Notes may also be of interest to practitioners:

  1. The role of documentary evidence in arbitration

  2. Disputes over documentary evidence in arbitration

  3. Evidence in international arbitration—the IBA Rules on the Taking of Evidence in International Arbitration

  4. Electronic evidence in arbitration

What is document production in international arbitration?

In the context of international arbitration proceedings, document production is associated with the process of collecting and presenting evidence. Document production is

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