a statement of the facts and the legal arguments supporting the respondentâ€™s defence; and
to the extent possible, the documentary evidence the respondent intends to rely on.
CHAPTER IV PROCEEDINGS BEFORE THE ARBITRAL TRIBUNAL
31.3 Any counterclaim or set-off claim by the respondent shall be raised no later than in the Statement of Defence, unless the arbitral tribunal in exceptional circumstances determines that the respondent has a justified reason to raise a counterclaim or set-off claim at a later stage of the proceedings. Any such counterclaim or setoff claim shall comply with the requirements of Article 31.1(a)-(c). 31.4 The arbitral tribunal shall, after consulting with the parties, decide the number, sequence and schedule of further written submissions (if any) by the parties following the filing of the Statement of Claim and the Statement of Defence. 31.5 Subject to any contrary agreement by the parties, a party may amend its claims during the course of the proceedings, unless the arbitral tribunal considers it inappropriate having regard to the delay in making the amendment or any other relevant circumstances.
PLEAS AS TO THE JURISDICTION OF THE ARBITRAL TRIBUNAL
32.1 The arbitral tribunal shall have the power to rule on its own jurisdiction, including any objections concerning the existence, validity or applicability of the arbitration agreement. 32.2 As a rule, a plea that the arbitral tribunal lacks jurisdiction shall be raised no later than in the Statement of Defence or, with respect to a counterclaim or set-off claim, in the reply to the counterclaim or set-off claim. The arbitral tribunal may admit a later jurisdictional plea only in exceptional circumstances, if it considers the delay in making the plea justified.