The closing statement in this case should be the final part of that quote: telling them what you've told them in a short succinct way to sum up everything you've said before. Avoid getting tangled up in analysis by focusing on the main points of what you meant to convey and summarising them effectively.
In conclusion, an effective opening statement will tell the arbitrator in a concise, courteous fashion exactly what the factual situation in the case is, what the issues are, how the advocate wants the arbitrator to rule on the issues, and exactly what relief is being requested.
There is no specific formula to close proceedings under any of the major arbitral rules. In practice, arbitral tribunals typically record their decision to close the proceedings in a procedural order 6 or a simple communication to the parties.
The Statement of Claim is a document you compose that provides the following: Name(s) of the claimant(s) — who is filing the claim. Name(s) of the respondent(s) — whom the claim is against. Details of the dispute.
Closing argument should tell the tribunal what actually happened at the hearing, take account of the full record as the evidence closes, and explain why the position laid out on opening was confirmed and vindicated. There can be no question that cases will develop during a hearing, sometimes substantially so.
Much like the opening statement in a trial, your arbitration statement should lay out what the “evidence” – the written material – will show regarding the proper credit on the project. The Arbitration Statement is not established fact, just your assessment of the material.
"A dispute having arisen between the parties concerning , the parties hereby agree that the dispute shall be referred to and finally resolved by arbitration under the LCIA Rules. The number of arbitrators shall be one/three. The seat, or legal place, of arbitration shall be City and/or Country.
Pleadings in Arbitration Proceedings The Respondent or Respondents are allowed to submit a responce to SoC by way of a 'Statement of Defence' (SoD) before the arbitral tribunal wherein they provide facts constituting the defence and other relevant information to rebut the claim raised by the Claimant.