Before Your Initial Conference

5. Mr. Bayer requires all the parties to schedule an Initial Arbitration Conference with him as soon after his appointment as possible. Carolina El'Azarwill call or email to schedule this Initial Arbitration Conference to take place either in-person or by telephone (if all parties agree).

Topics for this Initial Conference will include:

• Design of the Arbitration Process
• Scheduling Order
• Confidentiality Order
• Court Reporter and Written Record
• Necessary Discovery
• Rules of Procedure
• Rules of Evidence
• Dispositive Motions
• Reasoned or General Award
• KBDE Administration Policies
• Anything else you think should be brought to the arbitrator's attention about your particular dispute.

6. Prepare Yourself And Your Client for Your Initial Conference.

At your Initial Conference you will discuss the topics listed above. Mr. Bayer assumes you are well-informed about either the Texas Rules of Civil Procedure and Evidence or the Federal Rules of Civil Procedure and Evidence.

Before this conference convenes, Mr. Bayer recommends you also familiarize yourself with the rules of the AAA, the JAMS, and the ICC and the local rules of the US District Court, Western District, Austin Division, related to scheduling orders, confidentiality orders and pre-trial conferences.

You will also need to consider a checklist of questions posted here. Considering these questions prior to arriving at your Initial Arbitration Conference will prepare you to participate well on behalf of your client in the design of an arbitration process that meets the needs of all counsel and clients involved in the dispute.

Continue to During your arbitration process