'2. Time limits and extensions

2.1 The Sole Arbitrator shall set the time limits and extend them as necessary. For complying with a time limit, a notification must, if made by fax or e-mail, be sent to the Sole Arbitrator before expiration of the time limit; or if made by ordinary mail or courier service, be handed over to the postal or courier service prior to expiration (local time at the sender's place of business).

Always provided that the copies to the other addressees are notified at the same time and by the same or equivalent means.

2.2 In general, the extension of time limits shall only be granted exceptionally and provided that a request is submitted immediately after the event preventing the Party from complying with the time limit, but in any event before the expiration of the latter. In particular, a time limit that has been jointly agreed by the Parties and the Sole Arbitrator shall be extended only in extraordinary circumstances.

2.3 Unless a Party shows proof that it has been prevented to comply with the time limit by events outside of its control, the Sole Arbitrator may, but is not bound to, disregard a belated notification.

3. Evidence

With regard to the evidentiary proceedings the Sole Arbitrator shall take inspiration from the IBA Rules on the Taking of Evidence in International Commercial Arbitration without being bound by them.

3.1 Exhibits and documentary evidence

3.1.1 All exhibits and other evidence written in a language other than English shall be supplied together with an English translation. . . .

3.1.2 The paragraphs in the Parties' written submissions shall be numbered consecutively.

3.1.3 The Parties shall adduce in their written submissions all the evidence, e.g., documents, fact and expert witness statements, required to establish their arguments and, as the case may be, request the production of specific documents or witness testimony of documents/witnesses over which it has no control.

3.1.4 The exhibits submitted to the Sole Arbitrator shall be attached to the Party's written submission which first refers to them, In addition, the exhibits submitted to the Sole Arbitrator shall be accompanied by a list specifying at least their respective date and author.

3.1.5 The exhibits submitted by each Party shall be numbered consecutively throughout the entire proceedings. . . .

3.1.6 The Sole Arbitrator may request the Parties to submit a consolidated bundle of all exhibits and/or a chronological list of all dated exhibits in the course of the arbitration.

3.1.7 All documents submitted to the Sole Arbitrator are deemed valid and complete, including those submitted in copy form, unless the other Party disputes their authenticity. Unless otherwise agreed between the Parties or authorized by the Arbitrator, the documents so produced shall be complete and unaltered.

3.1.8 If any of the Parties refuses to produce a document upon a simple request by the other Party, the Sole Arbitrator shall have the power, upon specific and precise request of one of the Parties, to order the Parties to produce document(s) in their possession or under their control.

Any such request shall be in conformity with the IBA Rules on the Taking of Evidence in International Commercial Arbitration. . . .

3.2 Witness testimony

3.2.1 Anybody, including the Parties and their representatives, may be a witness.

3.2.2 The Parties or their Counsel may interview possible witnesses prior to their hearing.

3.2.3 The witnesses whose examination is requested shall be designated by their full name, occupation and address.

3.2.4 The witnesses shall in principle be summoned to appear by the Parties.

3.2.5 The costs of a witness appearance shall be borne by the Party summoning him or her. The Sole Arbitrator decides, in an award, on the respective allocation of such costs based on the Parties' request and evidence for costs incurred.

3.2.6 A witness duly summoned, who does not appear at the hearing of the Sole Arbitrator scheduled to hear his testimony, shall, in principle, only be summoned a second time on presentation of a valid excuse.

3.2.7 The Parties shall submit written witness statements with their briefs in accordance with Art. 4.5 of the IBA Rules on the Taking of Evidence International Commercial Arbitration.

3.2.8 Should a witness who has submitted a written statement not appear at the witness hearing, the Sole Arbitrator shall at its discretion assess his written statement, taking into account all relevant circumstances.

. . . . . . . . .

4. Hearings

4.1 When a hearing of witnesses is to be held the procedure shall in principle be as follows:

The witness shall first be invited by the Sole Arbitrator to confirm or deny, as the case may be, his or her written statement. In principle, the written statement substitutes for the oral examination by the party which summoned the witness and obtained his written testimony. However, if so requested, the Sole Arbitrator shall authorize a brief direct examination of the witness. Thereafter, the witness shall be cross-examined by the other party, followed by a re-direct and re-cross-examination by the respective party.

The Sole Arbitrator reserves to hear several witnesses at the same time ("witness conferencing") if in the Arbitrator's opinion this would significantly facilitate the taking of evidence. The Arbitrator will consult with the Parties before making a respective decision.

4.2 The witness examinations shall be English. If testimonies are made in a language other than English they shall, in principle, be translated. In such a case, a competent interpreter shall be arranged for and paid by the Party offering the respective witness and confirmed by the Sole Arbitrator.

4.3 The Sole Arbitrator may appoint court reporters to take verbatim transcripts of witness hearings. For other hearings, the Arbitrator may ask the Administrative Secretary, if any, or a secretary to take summary minutes.

4.4 The Sole Arbitrator shall, at all times, have a complete right of control (in accordance with Article 182 par. 3 of the Swiss Private International Law Statute) over the procedure in relation to the examination of a witness, including the right to limit or refuse the right of a Party to examine a witness when it considers that the factual allegation(s) on which the witness is intended to depose is sufficiently proven by exhibits or other witnesses or that the particular witness deposition as such is irrelevant.'