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Stipulations

Well-drafted stipulations narrow the issues, shorten the hearing, and focus the record on what the parties genuinely dispute.

What the parties may stipulate

  • A joint statement of the issue(s) to be decided
  • Facts not in dispute
  • Authenticity and admissibility of exhibits
  • Joint exhibit lists
  • Witness lists and order of proof
  • Procedural agreements (hearing format, briefing schedule, timeliness/arbitrability)
  • Submission and post-hearing deadlines

The stipulation process

After a matter is opened and the appointment is accepted, the parties confer and propose stipulations. Areas of agreement are compiled into a joint stipulation sheet that is confirmed by both sides before the hearing.

Stipulations are the parties' own agreements. The arbitrator does not draft the parties' positions or decide contested facts before hearing; the arbitrator's decision follows the record.

Stipulation exchange is coordinated after a matter is opened. Secure portal functionality for exhibit and stipulation exchange may be provided by invitation for active matters; it is not a public feature and is not represented here as fully operational. See Portal.