Memorandum for Respondent – work already started

On 6th December our team submitted Memorandum for Claimant. As  counsels of Mediterraneo Exquisite Supply (Claimant) we requested the Arbitral Tribunal to find that:

• The delay in delivery of goods contracted with Respondent occurred;
• The witness statement submitted by Respondent should not be considered;
• The oral amendment, in virtue of the reservation under CISG article 96 made by Mediterraneo, was null and void;
• Even according to Mr. Short’s witness statement, Mr. Long (Claimant’s contracting officer) did not intend to modify the Contract;
• CLAIMANT duly avoided the Contract.

Now we are ready to prepare Memorandum for Respondent. The deadline is 17 January 2013. We respond to the memorandum submitted by the University of Montpellier.