The Requesting Party is to fill in

The Requesting Party is to fill in the first, second and third rows of each Request. The first row sets out the number of the document request. In the second row, the Requesting Party is to provide a brief description of each document or category of documents requested so that the documents requested are clearly identified. The third row is to describe specifically why each document or category of documents requested is believed to be in the possession, custody or control of the Answering Party, and is both relevant to and potentially material to the outcome of the arbitration with references to the relevant paragraphs in the pleadings;