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(4) the party was not given a proper opportunity to argue his arguments or present his evidence;
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(10) There is a ground on which a court would have annulled a final judgment on which there is no longer an appeal."
The Respondent argues that the arbitration proceeding was forced upon him under pressure and threats, after the Applicant unilaterally informed him of the conduct of the proceeding, the identity of the panel and the date of the hearing. In this framework, the Respondent complains that if he had insisted on his procedural rights at the very beginning of the proceeding, the proceeding would have taken place in his city of residence, and in addition, he claimed that there was a difficulty with their sectoral affiliation with the Applicant - an ultra-Orthodox Sephardi, while he himself is a Hasidic. With regard to the fact that in the arbitration deed the respondent was defined as a 'plaintiff' - a status that ostensibly indicates that the choice of the court and the composition of the arbitrators was given to him - the respondent argues that this was a mistake. According to the Respondent, at a later stage, in the third judgment, and after two previous hearings had already been held and two previous judgments had been rendered, the Applicant was actually 'crowned' as a plaintiff in the proceeding.
With regard to the conduct of the arbitration, the Respondent argues that there were material failures in the proceeding, which deprived him of a proper opportunity to present his arguments and prove them as follows:
Violation of the right to a plea and the rules of natural justice: Every time the respondent tried to present his position, the applicant remained silent with shouting and threats in a libel suit. His procedural rights were impaired by the holding of the hearings late at night - an unreasonable date that prevented him from bringing his witnesses, as well as due to the lack of an orderly protocol and a sweeping prohibition on recording the hearings.