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(i) That the adjudicator had no jurisdiction to determine the dispute on the ground that the Notice of Adjudication issued by the plaintiff referred only to the original contract concluded in October 2001 and not to any further or extended contract applicable beyond 31 December 2006.
(ii) That the contract was not a "contract in writing" as required by the 1997 Order and therefore was not subject to the provisions of the Order.
(iii) That if the adjudicator had jurisdiction and made a valid award I should refuse enforcement of same on the ground that the defendants have entitlement to a Set Off in a sum greatly in excess of that due to the plaintiff.
(iv) That if the adjudicator had jurisdiction to make a valid award, and the defendants were not entitled to a Set Off, I should grant a stay of any judgment which I might otherwise issue pending resolution of the Set Off claim at arbitration. Proceedings in respect of the Set Off have been the subject of a referral to arbitration although proceedings are at an extremely early stage and will clearly not be determined for a very considerable period of time.
There followed some e-mails correcting the typographical error of "31 June" which should have read 31 March 2008.
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Common Room
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