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Clause Generator Step 1: Choose Case Type. Choose the type of arbitration clause you need (current or future dispute). Step 2: Customize Your Clause. Customize your clause by selecting the tabs of the wizard that apply to your situation, then fill in your information and the proper limitations. Step 3: Create a document.

It should state whether a panel of one or three arbitrator(s) is to be selected, and to include the place where the arbitration will occur. If the contract includes a general choice of law clause, it will govern the arbitration proceeding. Its consequences should be carefully thought through.

Example 1. Arbitration. All claims and disputes arising under or relating to this Agreement are to be settled by binding arbitration in the state of insert state in which parties agree to arbitrate or another location mutually agreeable to the parties.

Rule 37(a) provides relief to a party seeking discovery against one who, with or without stated objections, fails to afford the discovery sought.

Every arbitrator must be and remain impartial and independent of the parties involved in the arbitration. Before appointment or confirmation, a prospective arbitrator shall sign a statement of acceptance, availability, impartiality and independence.

Article 20. 20.1 Subject to these rules, the Tribunal may conduct the arbitration in whatever manner it considers appropriate, provided that the parties are treated with equality and that each party has the right to be heard and is given a reasonable opportunity to present its case.

Rule 20. (b) The Arbitrator may require that each Party submit a concise written statement of position, including summaries of the facts and evidence a Party intends to present, discussion of the applicable law and the basis for the requested Award or denial of relief sought.

This standard requires proposed arbitrators to disclose to all parties, in writing within 10 days of service of notice of their proposed nomination or appointment, all matters they are aware of at that time that could cause a person aware of the facts to reasonably entertain a doubt that the proposed arbitrator would ...

Never say anything to an arbitrator unless you are 100% sure it is correct. If you don't know the answer to a question, simply say, “I don't know the answer but will get it for you promptly.” Arbitrators respect lawyers who can zealously advocate for their clients and work out procedural issues with opposing counsel.