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.
"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.
Once the arbitrator decides that all of the parties' evidence and arguments have been presented, the arbitrator will close the hearings. This means no more evidence or arguments will be allowed.
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.
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.
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.
byStep Guide to Creating an Opening Statement Understand the Purpose. Know Your Audience. Structure Your Statement. Be Clear and Concise. Tell a Story. Establish Credibility. Practice. Avoid Overpromising.
Under Rule 25, commercial and personal injury cases with damages valued at less than $50,000 and that do not involve claims of medical malpractice, asbestos, construction, nursing home, and product liability are automatically referred to mandatory arbitration.