(a) that the Claimant has waived its right to respond to the Respondent's arguments which it has chosen not to address in its Opposition;40 or if the Tribunal is to revise the briefing schedule and allow the Claimant to address the Respondent's arguments, (i) the Respondent must be granted an equal opportunity to respond; and (ii) the Claimant should not be permitted to address any of the Respondent's arguments for the first time at the Hearing;41
(b) that it be permitted to brief, and that the Tribunal decide as a preliminary question in accordance with the Tribunal's authority under Article 23(3) of the UNCITRAL Arbitration Rules, its objection pertaining to the waiver requirement;42
(c) that the Claimant comply with the provisions of the Tribunal's Procedural Order No. 1 with respect to the translations of documents; that it comply with the transparency provisions of the Treaty and the Tribunal's Procedural Order No. 1; and that the Claimant avoid other actions which unduly interfere with the arbitral procedure.43
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