REQUESTS FOR PRODUCTION OF DOCUMENTS WITHHELD ON ...

IV. Conclusion
39. In summation, the Tribunal as detailed above:
a. provides legal standards and definitions of the various privileges claimed by the
Parties that shall apply in these proceedings and that, the Tribunal anticipates,
can be used to reduce the number of withheld documents that remain in dispute;
b. outlines procedures for the Parties going forward to explain their objections to
and assertions of privilege, so as to facilitate further negotiations between the
Parties; and
c. states its willingness to decide upon objections to claims of privilege on specific
documents should the Parties be unable to reach agreement.
Signed November 17, 2005
__________________ __________________ __________________
David D. Caron Michael K. Young Donald L. Morgan
Arbitrator President Arbitrator
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