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Emergency relief for early production of evidence. Even though the construction company's activities had ceased for more than six months and the current state of the works may not correspond to the state at the time of the termination of the contract, the early production of expert witness evidence "upholds (…) the right to a full defense, while also preventing future allegations of curtailment of defense rights," since "it is not reasonable to compel the respondent to await the constitution of the arbitral tribunal, thereby losing the opportunity to record the current state of the works":

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