EN
TR
The parties, their lawyers and their experts must work together to present the evidence…
■ The “dump truck” approach, consisting in filing volumes and volumes of documents…
■ Conversely, only such evidence that is strictly necessary should be filed;…
■ The use of witnesses to prove quantum should be kept to a strict minimum because…
■ Broad requests for document production are rarely helpful in construction arbitration,…
Much can be gained if the arbitral tribunal and the parties can agree, at the outset…
■ The tribunal and the parties should seek ways to narrow down in advance areas of…
■ The parties (and their quantum experts) should seek to present quantum evidence…
■ It is established good practice to have quantum experts meet as early in the process…
■ The arbitral tribunal and the parties must devote sufficient time to quantum issues…
