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Set out below is an example of a Redfern schedule of the type commonly used for the exchange of requests for documentation between two parties in international arbitration proceedings where the parties have agreed to the application IBA Rules on the Taking of Evidence in International Arbitration—see Practice Note: Evidence in international arbitration—the IBA Rules on the Taking of Evidence in International Arbitration. The example below is a claimant-side Redfern schedule, but a similar schedule would be completed by the respondent. It is typical for both schedules to be exchanged simultaneously, though this is a matter for the procedural timetable in the arbitration. This Precedent may be read alongside Practice Note: Document production in international arbitration—a practical guide.
The precise format of a Redfern schedule can vary and should be agreed between the parties or determined by the tribunal (usually in consultation with the parties). There are various formats that the parties can adopt, including the Stern schedule, which sets out the requirements for a request and any response vertically rather than horizontally, and the Armesto schedule, which seeks to categorise the forms of objection a party can make to producing documents. The example below is the traditional horizontal Redfern schedule format and includes five substantive columns: (1) the claimant’s documentation requests; (2) the claimant’s position on relevance and materiality of its requests;
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Coronavirus (COVID-19): The guidance detailing normal practice set out in this Practice Note may be affected by measures concerning process and procedure in the civil courts that have been introduced as a result of the coronavirus (COVID-19) pandemic. For guidance, see Practice Note: Coronavirus
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