Preliminary Meeting in Arbitration - Agenda and Submissions

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Introduction

BETWEEN:

[INSERT NAME OF CLAIMANT] Claimant

-AND-

[INSERT NAME OF RESPONDENT] Respondent

Claimant's proposed agenda and submissions for preliminary meeting to be held on [insert date]

1 Prior to this preliminary hearing, the parties have sought to agree in correspondence on various procedural matters. [Refer to any key correspondence copied to the tribunal on these matters.]

2 The Claimant respectfully submits that the following key issues regarding the arbitration should be addressed at the procedural hearing:

  • 2.1 the applicable rules and law: [insert text, e.g.,: The parties agree that the arbitration shall be governed by [insert applicable arbitration rules][in force as of [insert date]]].

  • 2.2 seat and language: [[insert text, e.g.,: The parties agree that the seat of arbitration should be [insert place] and that the language of the arbitration should be [insert language]. Where documents are submitted in any language other than [insert language], they should be accompanied by translations.]].

  • 2.3 venue for hearings: [insert text].

  • 2.4 jurisdiction: [insert text].