1. Unless otherwise agreed by the parties or determined by the Arbitral Tribunal, the Claimant shall send to the Respondent and to each of the Arbitrators, within (14) fourteen days from the date of formation of the Arbitral Tribunal, a written statement of its claim that includes its name, address, the Respondent's name and address, an explanation of the facts of the case, the determination of the points at issue, the relief or remedy sought, and all other elements which are required to be mentioned in such statement by agreement between the parties. 2. Unless otherwise agreed by the parties or determined by the Arbitral Tribunal, the Respondent shall send to the Claimant and to each of the Arbitrators, within (14) fourteen days from the day following receipt of the statement sent by the Claimant, which is referred to in the previous item of this Article, a written statement of its defense in reply to the statement of claim. It may include in such statement of defense any incidental claims or counterclaims related to the disputed matter, or invoke a right arising out of the same for the purpose of a set-off, even at a later stage of the proceedings, provided that the Arbitral Tribunal deems that the circumstances justify the delay. 3. Unless otherwise agreed by the parties, any of the parties may modify or complete its motions or defenses or institute a countreclaim during the arbitral proceedings, unless the Arbitral Tribunal decides not to accept the same to avoid delaying adjudication of the dispute or because this matter falls outside its jurisdiction, provided that the Arbitral Tribunal shall take into account, while entering its award, the litigation principles and rights of the defense.
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