Tell me the basics that make this matter urgent

• In one short paragraph, summarize the dispute, the parties involved, and the specific remedy you are seeking.
• When did the underlying event or contractual breach occur, and what deadlines or statute of limitations affecting your case are already running?
• Tell me about any existing contract clause that governs dispute resolution in your agreement, including seat, choice of law, or discovery limits.
• Who on your team is enabled to select the forum and approve the budget for this matter? Options: In house counsel, Outside counsel, Board level signoff, CFO or legal operations, Other
• If you had to decide today, which factual or jurisdictional detail would cause you to rule out arbitration entirely?

Where the process usually gets stuck

• Which recurring procedural complication in past matters cost you the most time or money? Options: Narrow discovery disputes, Massive document requests, Third party subpoenas, Privilege litigation, Privilege waiver fights, Other
• How often do opposing parties use discovery tactics that materially delay hearings in your cases? Options: Almost always, Often, Sometimes, Rarely, Never
• Describe an example of a past case where discovery widened unexpectedly, what triggered it, and what the final impact on your schedule and budget was.
• Would ongoing discovery disputes or a contested neutral selection be a deal breaker for you, and under what condition would you walk away? Options: Yes, dispositive issues would stop us, Sometimes, depends on cost and timing, No, we would push through with motions

The other paths you are weighing

• Who or what are you actively considering instead of an administered forum right now? Options: Direct negotiation, Internal dispute committee, Litigation in court, Ad hoc arbitration, Another institution, Mediation, Other
• Which internal option, if any, has been proposed to keep this out of external administration? Options: Executive approval required, Board approval, Outside counsel signoff only, Budget threshold prevents external admin, No internal option proposed
• List the institutional or court based alternatives you have evaluated, and the top reason each was ruled in or out.
• What would need to be true about your current approach for you to stay with it rather than change to an administered process?
• Select up to two factors that would push you to choose litigation or in house resolution over an institution. Options: Lower upfront fees, Faster emergency remedies, Familiarity with internal counsel, Avoiding confidentiality concerns, Ability to subpoena evidence directly, Control over scheduling, Other

Which enforceability concerns actually matter in practice

• To what extent do enforceability risks in a key jurisdiction change your willingness to pursue arbitration? Options: Greatly reduces willingness, Somewhat reduces willingness, Little effect, No effect
• Identify the jurisdictions where enforcement of an award would be critical to your recovery, and why.
• Are there existing injunctions, insolvency proceedings, or export controls that could prevent enforcement or asset seizure in your case? Options: Yes, pending injunctions, Yes, insolvency or restructuring, Yes, export or trade controls, No anticipated bars, Unsure
• If enforcement in a principal revenue country is unlikely, do you still want to proceed under an administered framework? Options: Yes, for declaratory value or other remedies, No, we need enforceability, Depends on alternative collection routes

Discovery and evidence, where costs balloon

• How large do you expect document and e discovery volumes to be for this matter, and what drives that estimate? Options: Under 10,000 pages, 10,000 to 100,000 pages, 100,000 to 1,000,000 pages, More than 1,000,000 pages, Unknown
• Point to the categories of documents and data that will be hardest for your team to produce, for example cross border personnel records, privileged communications, or encrypted backups.
• Do you anticipate needing expert forensic collection, source code review, or privileged log analysis, and who would fund those experts? Options: Yes, expected and funded by us, Yes, expected and funding to be negotiated, No, not expected, Unsure
• Describe the level of redaction or culling your team considers acceptable to balance proportionality and case needs.
• Is there any privacy, data transfer, or regulatory bar that would make production impossible for you and therefore stop the process? Options: Yes, privacy or cross border laws block production, Yes, banking or industry secrecy rules, No blocking rule anticipated, Unknown

Picking the right neutral, not the convenient one

• Name the specialized experience a neutral must have for you to proceed, for example industry sector, technical training, or prior tribunal work. Options: Industry sector experience, Technical or engineering background, Financial or valuations expertise, Employment law expertise, Cross border enforcement experience, Language capabilities, Other
• Point out any categories of candidates you will reject on conflict or impartiality grounds, such as prior counsel roles or financial ties.
• Would you accept a panelist with deep technical knowledge but less prior arbitral experience, or is prior tribunal service required by your team? Options: Yes, technical knowledge acceptable, No, prior tribunal service required, Case dependent
• Select the action you will take if a shortlist lacks an acceptable neutral, pause the matter, litigate, or arrange ad hoc procedures. Options: Pause the matter, File in court, Accept ad hoc appointment, Renegotiate selection process, Seek expedited replacement

Scheduling, hearings, and cost expectations

• Assuming hearings run later than 12 weeks, what impact does that delay have on your client strategy or enforcement options?
• State your preferred hearing format and the trade offs you care about between virtual convenience and in person presence. Options: Fully virtual, Hybrid with some in person days, Fully in person, Written submissions with limited hearing
• Choose the fee structure your team can approve, select one. Options: Daily arbitrator rate, Per hearing day billing, Blended rate, Fixed fee cap, Phased payment schedule
• Do you have an internal budget ceiling for this matter, and if so, what is the approval threshold for cost variance?
• Decide how you will respond if total fees exceed your budget by 20 percent, stop, renegotiate, or absorb. Options: Stop the matter, Renegotiate fees, Absorb the overrun, Seek third party funding

Practical must haves before we file

• List the internal approvals or signoffs required before you can authorize filing and fee payments. Options: General counsel approval, Board approval, Finance signoff, Outside counsel confirmation, Operational signoff
• Identify the internal owners for document production, IT access, and vendor coordination in your organization.
• Are there regulatory filings, data transfer consents, or privacy notices your team must complete before cross border discovery begins? Options: Yes, filings required, Yes, consents required, No, none anticipated, Unsure
• Tell me whether a regulatory timeframe over 60 days would prevent you from pursuing arbitration. Options: Yes, it would stop us, No, we can wait, It depends on risk and cost

What will make you say yes

• Imagine we deliver a neutral shortlist, a procedural timeline, and a capped fee estimate within seven days, what would stop you from signing the administration agreement that week?
• Provide the metrics you will use to judge success at three months and at one year after an award.
• Pick the deliverable from the institution in the first week that would increase your confidence the most. Options: Neutral shortlist with CVs, Detailed procedural timeline, Transparent cost breakdown, Service contacts and logistics plan, Draft administration agreement
• Can your team sign an authorization to proceed immediately if the first month produces the necessary timeline and cost performance? Options: Yes, we can sign immediately, No, further approvals required, Only with specific conditions
• Name the final decision maker who approves the administration agreement.

• Process Walkthrough, Rules & Scheduling

• Confirm your current state and its cost
• You confirm which procedural rule set and discovery boundary would stop the escalation to litigation‑level costs.
• Provide the case chronology, key contested issues, and the list of implicated jurisdictions to the seller team within three business days.
• You agree on an acceptable neutral qualification profile and a target selection timeline that meets your scheduling constraints.
• Walk through procedural rule options with realistic scenarios
• Seller to deliver a tailored comparison of 2–3 procedural rule sets showing estimated time-to-hearing, projected administrative and legal costs, and enforceability notes within five business days.
• You identify the remaining evidence and decisions required to finalize institutional rules and a fee cap to present to the other side.
• Demonstrate discovery boundary examples and cost impact
• Buyer to confirm any absolute non‑negotiable discovery items or minimum neutral qualifications in writing before the selection stage.
• Review hearing formats and scheduling trade-offs
• Jointly confirm a neutral selection window and hearing length target so the seller can produce a short‑list aligned to availability.
• Validate the proposed procedural plan

• Process Walkthrough, Rules & Scheduling
• Process Walkthrough Deck
• Process Walkthrough Brief

• meeting
• slides
• document

• Register and Docket Arbitration Case
• Apply Institutional Procedural Rules Package
• Provide Curated Neutral Roster with Credentials
• Operate Secure Case Management Portal
• Provide eDiscovery Document Production Platform
• Administer Document and Exhibit Numbering
• Provide Hearing Facilities and Technical Support
• Operate Virtual Hearing Platform and Tools
• Produce Certified Hearing Transcripts and Recordings
• Issue and Certify Final Awards and Reasoned Decisions
• Prepare Award Package for Cross‑Border Enforcement
• Manage Fees, Deposits, and Financial Accounting
• Handle Multi‑Party Joinder and Consolidation Filings
• Provide Expedited Interim Relief (Provisional Measures)

Register and Docket Arbitration Case

• Confirm whether you have a fully executed arbitration agreement or clause to support case registration and attach the executed text or clause citation. Options: Yes, executed clause attached, No, draft or missing
• For registration, provide the enforcement jurisdictions (countries or states) where you plan to seek recognition of an award and the governing law named in the clause.
• Regarding docketing, specify the filing party, the primary docketing contact email, and the formal service address for notices.
• For party counts, estimate how many claimants and respondents require separate party records on the docket. Options: 1 claimant / 1 respondent, 2-5 parties total, 6+ parties / complex multi-party
• For timing, state the proposed filing date you want used for case timing and statute of limitations calculations.
• Regarding existing orders, are there pending court stays, tolling agreements, or interim injunctive orders that affect your proposed filing date? Options: Yes, No

Apply Institutional Procedural Rules Package

• Select the procedural rules package you propose to apply (institutional rules, UNCITRAL Rules, or a hybrid) and reference the arbitration clause provision that supports that choice. Options: Institutional rules, UNCITRAL Rules, Hybrid / bespoke (describe)
• For the rules, list any specific articles or provisions you intend to invoke such as expedited procedure, emergency arbitrator, document production limits, and cite article numbers if available.
• Regarding rule modifications, name the internal person authorized to agree to procedural waivers or emergency measures and provide contact details.
• For scheduling controls, indicate any mandatory timelines you require for key stages (for example initial disclosures within 30 days, hearing within 120 days). Options: 30 days for initial disclosures, 60 days, Custom timeline (specify)
• For confidentiality, do you require enhanced protections beyond standard rules such as trade-secret designation, sealed filings, or special redaction protocols? Options: Yes, No
• Regarding discovery proportionality, provide the thresholds you expect expressed as maximum custodians, date ranges, or total GB to guide production limits.

Provide Curated Neutral Roster with Credentials

• For shortlists, how many neutral candidates do you want presented per party or jointly (for example 3 to 5 candidates)? Options: 3, 4, 5, Other (specify)
• Concerning expertise, specify the subject-matter areas required (for example construction delay, maritime charter party, cross-border M&A) and minimum years of experience expected.
• Regarding languages and seats, indicate whether neutrals must have specific language fluency or tribunal-seat familiarity (for example Spanish fluency, experience with New York seat). Options: Yes, No
• For conflicts, list disqualification criteria to apply during checks, such as prior counsel relationships, equity holdings, or repeated appointments by a named counterparty.
• On documentation, choose the credential package you expect for each candidate: CV, representative case list, published rulings or awards, and fee schedule. Options: CV only, CV + case list, Full package (CV + cases + rulings + fees)
• Identify the individual on your side who will approve the final neutral selection and provide their contact information.

Operate Secure Case Management Portal

• For access planning, describe required user roles and permissions for the portal (for example case administrator, counsel, arbitrator, external expert) and list approximate user counts per role.
• Concerning controls, which document access restrictions are mandatory for you (for example view-only, download disabled, watermarking, or time-limited links)? Options: View only, Download allowed, Watermarking required, Time-limited links
• What evidence will validate secure portal access and auditability for your acceptance tests (for example SOC 2 report, role-based audit log export, or a successful SAML single sign-on test)? Options: SOC 2 or equivalent report, Sample audit log export, Successful SAML / Single Sign-On (SSO) test
• For retention, state the required storage period for case files and exhibits and note any cross-border data residency constraints that must be enforced. Options: 7 years, 10 years, Custom (specify)
• Regarding e-signatures, do you require embedded e-signature or document-sealing workflows for confidential submissions and redactions? Options: Yes, No
• Designate who will run portal onboarding and training for your users and indicate preferred date windows for onboarding sessions.

Provide eDiscovery Document Production Platform

• For sizing, estimate expected document volume in number of documents and total gigabytes to size the production platform and technology-assisted review (TAR) needs. Options: Less than 10,000 / <100GB, 10,000-100,000 / 100GB-1TB, More than 100,000 / >1TB, Estimate later
• Regarding content types, which document types predominate in your matter (for example emails, contracts, invoices, technical drawings, source code)? Options: Emails, Contracts, Financial records, Technical drawings, Source code, Other
• Indicate whether you require native privilege and redaction logs in CSV format and a Bates-stamped image set for productions. Options: Yes, No
• For preservation, detail any custodians, preservation holds, and date ranges you have already identified or issued preservation notices for.
• Define the production load file format and metadata fields you require (for example TIFF/PDF load files, extracted text, TO/FROM dates, and attachment linking).
• Name the eDiscovery contact on your side who will manage FTP/SFTP transfers and chain-of-custody documentation.

Administer Document and Exhibit Numbering

• Describe your preferred bates and exhibit numbering format and prefix (for example PARTYA_0001 or EXHIBIT 1-A) to be used across pleadings and productions.
• For multi-party matters, will you require consolidated numbering for productions or separate party series? Options: Consolidated numbering, Separate series per party, Hybrid (specify)
• Outline the exhibit authentication process and chain-of-custody stamping you require for physical evidence admitted at hearing.
• Supply the number of printed hearing bundle sets you will need if printed bundles are required, and indicate whether electronic-only bundles are acceptable. Options: Electronic only, Electronic + 2 printed sets, Electronic + multiple printed sets (specify)
• Detail any exhibit numbering exceptions such as pre-admitted documents or confidential exhibits that should be excluded from public bundles.
• Who will be the document owner responsible for approving the final exhibit index and numbering on your side (provide name and contact)?

Provide Hearing Facilities and Technical Support

• For in-person hearings, select the preferred venue format: single courtroom-style, multiple breakout rooms, or hybrid with livestream capabilities. Options: Courtroom-style, Breakout rooms, Hybrid with livestream
• Identify preferred hearing cities or venue selection criteria such as proximity to counsel, visa access, courtroom size, and ADA compliance.
• Give the expected hearing length in days and session hours per day so room reservations and staffing can be arranged. Options: Half-day sessions, 1-2 days, 3-5 days, More than 5 days
• Share whether on-site technical support is required for AV, simultaneous interpretation, or secure electronic evidence presentation. Options: AV only, AV + interpretation, Full technical support including evidence presentation, None
• Outline catering needs, security levels, and witness waiting-room requirements for an in-person hearing.
• Designate the local logistics lead and emergency contact for the hearing dates and provide name and telephone number.

Operate Virtual Hearing Platform and Tools

• Enumerate the virtual hearing features you require such as HD video quality, breakout rooms, exhibit sharing, live annotation, polling, and interpreter channels.
• Note browser and operating system compatibility constraints for participants, including mobile access and corporate firewall or VPN restrictions.
• What technical acceptance criteria must be met before scheduling (for example a recorded test session with counsel, measured latency below a threshold, and verified participant authentication)? Options: Recorded test session with all counsel, Latency under 200 ms, Two-factor authentication enabled
• For capacity planning, how many simultaneous participants and remote witness audio/video feeds must be supported at peak? Options: Up to 10, 10-25, 25-100, 100+
• Choose whether you require integrated real-time transcription, live stenography feeds, and closed-caption exports for virtual sessions. Options: Real-time transcription, Stenographer feed, Both, None
• Identify the party or vendor responsible for remote witness identity verification and any notarization or attestation workflow required.

Produce Certified Hearing Transcripts and Recordings

• Declare the transcript and recording deliverable you require: certified court-reporting transcript, verbatim stenography, or audio-only certified recording. Options: Certified transcript, Audio-only certified recording, Both
• Attach the required transcript turnaround time and delivery format (for example same-day rough transcript, 3 business days, or 7 business days final). Options: Same-day rough, 3 business days, 7 business days, Custom timeline
• Mark whether you require timestamps, exhibit linking, and speaker identification included in the delivered transcripts. Options: Timestamps, Exhibit linking, Speaker identification, All of the above
• Note any jurisdiction-specific transcript certification requirements we must meet for enforcement filings, for example notarized certification or court-specific attestation.
• Who on your team will be authorized to request transcript corrections and within what timeframe after initial delivery?
• Mark whether verbatim recordings are required to be stored in the secure portal with restricted access for a specified retention period. Options: Yes, No

Issue and Certify Final Awards and Reasoned Decisions

• Declare whether you require a reasoned award, a summary award, or a consent award and note any mandatory legal language needed for enforceability in your target jurisdictions. Options: Reasoned award, Summary award, Consent award, Other (specify)
• What acceptance criteria will confirm issuance and certification of the final award for your sign-off (for example signed tribunal award, authenticated PDF with institutional seal, registrar certificate)? Options: Signed tribunal award, Authenticated PDF with institutional seal, Registrar certificate of issuance
• Clarify whether copies of the award should be apostilled or consularly legalized for the enforcement jurisdictions you named. Options: Apostille, Legalization (consular), Not required, TBD
• Clarify the designated recipient for the official award and the preferred delivery method (secure portal + email, courier, or both). Options: Secure portal + email, Courier service, Both, Other (specify)
• Outline any redaction or confidentiality markings required on the public or shared version of the award.
• Provide the expected timeline from closing submissions to award issuance measured in business days. Options: 30 days, 60 days, 90 days, Custom (specify)

• Master Administration Agreement (MAA)
• Statement of Work (SOW)
• Institutional Rules Election Addendum
• Fee Schedule & Payment Terms
• Deposit & Payment Authorization
• Authorization to Proceed & Appointment Confirmation
• Data Processing Agreement (DPA) — conditional

• Award Issuance and Delivery Check
• First Measurement Review, Post-Award (weeks 4-10)
• Acceptance Gate and Formal Case Close Decision (around day 90)
• Quarterly Post-Award Enforcement Review

• Schedule the next quarterly review and any interim checkpoints for high-risk matters.
• Remediation items for any failed criteria are agreed with deadlines and owners.
• Publish the acceptance decision document and archive it with the case record.
• Log remediation items with target completion dates and track them in the shared channel.
• Update the case closure checklist and evidence archive to reflect accepted outcomes.
• Notify relevant parties that the acceptance gate decision has been recorded and next steps are scheduled.
• Review open enforcement docket
• The active enforcement docket is reconciled and prioritized with next actions assigned.
• Median time-to-resolution is reviewed and outliers are assigned remediation steps.
• A prioritized list of enhancement requests and process improvements is agreed for the next quarter.
• Update the enforcement docket with current statuses and next action dates.
• Create remediation tasks for cases exceeding median time-to-resolution and track progress.
• Publish the prioritized enhancement request log and assign owners for implementation work.
• Confirm final award document
• Final award document and proof of service are on file and their locations are confirmed.
• A shared post-award communication channel exists and primary contacts are documented.
• Any immediate enforcement steps required within 30 days are identified with remediation tasks and due dates.
• Circulate the certified final award and the proof of service to the shared channel.
• Publish the post-award communications contact list and channel link.
• Document immediate enforcement steps required in the next 30 days with dates and owners.
• Produce a short lessons-learned note for the case file.
• Present metric report
• Confirm the current days-from-issuance-to-service and the number of enforcement proceedings initiated, and record whether they are on track to meet the case targets.
• Assign corrective actions with dates to close any identified gaps before the acceptance gate.
• Agree any evidence or counsel actions needed to support enforcement filings.
• Publish the metric report showing days from award issuance to confirmed service and the count of enforcement proceedings initiated.
• Document and schedule corrective actions with completion dates and owners.
• Update the enforcement playbook with newly identified evidence requirements and filing timelines.
• Prepare materials required for the acceptance gate meeting.
• Restate acceptance criteria
• Each acceptance criterion recorded in Case Intake & Outcome Discovery is evaluated and recorded as pass or fail.
• A documented acceptance decision is published, including a named signatory where required for managed engagements.
• Verify delivery and proof of service
• Measure time-to-resolution trends
• Present outcome data against each criterion
• Diagnose root causes for gaps
• Agree corrective actions and timeline
• Capture enhancement requests and process improvements
• Document pass or fail and record formal decision
• Open immediate enforcement considerations
• Establish post-award communication channel
• Update enforcement strategy and evidence needs
• Agree next quarter priorities and checkpoints
• Agree remediation plan for failed criteria
• Capture lessons learned and open issues