Redfern Schedule - Arbitration

Drafting notes

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. 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.

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). The example below includes five substantive columns: (1) the claimant's documentation requests; (2) the claimant's position on relevance and materiality of its requests; (3) the respondent's response to the claimant's requests; (4) any reply from the claimant on the respondent's response to requests; and, (5) the arbitral tribunal's decision and/or order.