'1. Except as otherwise established by the Tribunal, the course of the arbitration will be governed by the IBA Rules on the Taking of Evidence in International Commercial Arbitration ("IBA Rules").

2. Article 3 of the IBA Rules shall govern the production of documents. On or before July 9, 2004, and in accordance with Article 3 of the IBA Rules, each Party shall submit to the other Party all documents available to it on which it relies, including public documents and documents in the public domain. The Parties will seasonably supplement their disclosure of documents as new documents are found, become available, or are subsequently determined by the Party to be a document upon which it relies as a part of its claims or defences. Each Party shall exercise good faith in identifying documents upon which it relies. Copies of the documents will not be given to the Arbitral Tribunal, but will be later submitted as proposed exhibits in accordance with paragraph 12 of this Stipulation.

3. On or before July 9, 2004, and in accordance with Article 4 of the IBA Rules, the Parties shall use their best efforts to identify all witnesses on whose testimony they rely, and the subject matter of such testimony, and shall seasonably supplement such disclosure.

4. On or before May 14, 2004, each Party shall submit to the Arbitral Tribunal and to the other Party any Request to Produce Documents. The Request to Produce Documents shall follow the procedures identified in Article 3 of the IBA Rules. The Party to whom a Request to Produce Documents is directed shall: (1) within 15 calendar days of receipt of the Request produce to the other Party all documents in its possession, custody or control as to which no objection is made; and (2) within 15 calendar days of receipt of the Request submit to the other Party and the Arbitral Tribunal any objections to the Request to Produce Documents. The Arbitral Tribunal shall, in consultation with the Parties and in a timely fashion, consider the Request to Produce Documents and the objections and may enter such orders as authorized by Article 3 of the IBA Rules. The Parties shall, prior to the submittal of any Request to Produce Documents to the Tribunal, make a good faith effort to resolve issues regarding the production of documents without resort to the Arbitral Tribunal.

5. On or before August 13, 2004, the Parties shall take whatever steps are legally available to obtain production of documents from a person or organization who is not a Party to the Arbitration. Any requests to produce documents directed to a person or organization who is not a Party to the Arbitration shall follow the procedures set forth in Article 3.8 of the IBA Rules. The Parties stipulate that the Federal Arbitration Act (FAA) shall govern the obtaining of documents and testimony from third parties. Each Party shall reasonably cooperate in the efforts of the other Party to obtain evidence from third parties, including, where appropriate, consenting to the release of information by third parties. The Arbitral Tribunal shall have authority to resolve any dispute between the Parties over such cooperation and shall have the authority to order either Party to consent to the release of information by third parties.

6. Article 5 of the IBA Rules shall govern Party-Appointed Experts and Expert Reports. Claimant shall submit any Article 5 Expert Report(s) to Respondent and the Arbitral Tribunal on or before August 6, 2004. Respondent shall submit any Article 5 Expert Report(s) to Claimant and the Arbitral Tribunal on or before September 10, 2004. Experts may seasonably supplement their reports based on evidence developed or disclosed subsequent to submittal of their initial reports. The Parties will seasonably supplement their disclosure of documents as new documents are found, become available, or are subsequently determined by the Party to be a document upon which it relies as part of its claims or defenses.

7. On or before September 29, 2004, each Party shall submit to the other Party and the Arbitral Tribunal a written statement by each witness on whose testimony that Party relies, unless such witness is affiliated with the other Party. Witness statements shall conform with Article 4.5 of the IBA Rules.

8. On or before October 27, 2004, each Party shall submit to the other Party and the Arbitral Tribunal any revised or additional Witness Statements as authorized by Article 4.6 of the IBA Rules and subject to its limitations.

9. Each witness for whom a Witness Statement has been submitted shall appear for testimony at the evidentiary hearing, unless the Parties agree otherwise. The Parties shall seasonably notify the Arbitral Panel of any such agreement.

10. On or before August 20, 2004, in accordance with Article 4.10 of the IBA Rules, any Party wishing to present evidence from a person who will not appear voluntarily at the Party's request may ask that the Arbitral Tribunal take whatever steps are legally available to obtain the testimony of that person. Each Party shall cooperate in the efforts of the other Party to obtain the testimony in the same manner as outlined in paragraph 5 of this Stipulation related to documents. The Parties shall follow the procedures outlined in Article 4.10 in submitting such requests to the Arbitral Tribunal.

11. On or before October 15, 2004, each Party shall submit to the other Party and the Arbitral Tribunal an Arbitration Memorandum. The Arbitration Memorandum shall set forth the facts and legal authorities upon which the Party relies in support of its claims. Article 19 of the ICC Rules of Arbitration shall control the assertion of new claims, if any. A Party's Arbitration Memorandum may not assert new claims in contravention of Article 19.

12. Prior to the Hearing, the Parties shall arrange for the joint presentation of exhibits at the hearing. The exhibits shall, to the extent possible, be chronologically arranged. The Parties may also choose to arrange the exhibits by subject matter.

13. The hearing of this matter shall take place in Dallas, Texas, at a venue to be arranged by the Tribunal, in consultation with the Parties, and shall begin on November 15, 2004.

14. In advance of the hearing, the Arbitral Tribunal will set a date, in consultation with the Parties, for a telephone conference to address any outstanding issue and, in particular, to address further means by which the Arbitral Tribunal shall proceed to establish the facts of the case.

15. The respective claims of the Parties relative to attorneys' fees shall be resolved subsequent to the resolution of the case on the merits.'