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JdR Arbitration Rules

The following arbitration rules will be applied by the panelists at Judicial Dispute Resolution where not in conflict with the requirements of Washington law (see RCW Chapter 7.04A, the Uniform Arbitration Act). The goal of these rules is to provide parties to civil disputes with fair, private, expeditious and final decisions. If the parties agree to other rules or procedures, they will be enforced as long as not contrary to law. Where an issue is not covered by these rules or by stipulation of the parties, the Superior Court Rules (CR), the Local Rules of the Superior Court for King County (LR) and RCW 7.04A, et seq., will govern.

  1. Commencement of an Arbitration: An Arbitration is commenced when the parties agree to arbitrate or either party serves a Notice of Intention to Arbitrate consistent with RCW 7.04A.090 on the other party or parties and on Judicial Dispute Resolution, describing the nature of the controversy and the remedy sought.
  2. Selection of an Arbitrator: If the parties have not agreed upon an arbitrator, Judicial Dispute Resolution will provide them with a strike list within seven days of receipt of the Notice of Intention to Arbitrate. The parties will attempt to agree on an arbitrator. If agreement is not reached, each party will return the strike list and the case administrator will notify you of the arbitrator appointment. If the parties do not return the strike list, JdR will deem all arbitrators to be acceptable.
  3. Initial Conference Call: Within seven days of service on Judicial Dispute Resolution of Notice of Intention to Arbitrate which designates an arbitrator, or upon selection of an arbitrator from the strike list, Judicial Dispute Resolution will conduct an initial conference call between the arbitrator and the parties. During this initial conference call, a hearing date will be selected and a discovery schedule arranged. Consistent with the goal of providing an expeditious decision, the hearing will be held within 90 days of the initial conference call, unless the arbitrator decides otherwise.
  4. Discovery Schedule: Consistent with the goal of an efficient resolution of the dispute, discovery will be limited to matters essential to establish or defend the claim. Therefore, absent the agreement of the parties or other order of the arbitrator, each side will be allowed to propound not more than five requests for production of documents, five interrogatories and take not more than three depositions each lasting no longer than four hours.
  5. Pre-hearing matters: Disputes that develop prior to the hearing which cannot be resolved by the parties will be determined by telephone conference call or by written motion.
  6. The Arbitration Hearing: Unless agreed otherwise, the arbitration hearing will be conducted at the offices of Judicial Dispute Resolution. The parties are expected to attend, either in person or by counsel. The arbitrator will consider all evidence which appears to the arbitrator to be relevant to the dispute, including, but not limited to, bills, reports, photographs, videotapes or other documentary evidence, and written statements of witnesses. Such evidence will be considered by the arbitrator if the proponent has served a copy on all parties, and has provided the name, address and phone number of the author, at least 14 days prior to the hearing. Enforcement of this rule will be consistent with the enforcement of Superior Court Mandatory Arbitration Rule 5.2.
  7. The Arbitration Award: The arbitrator will make every effort to issue a written award within five working days of the conclusion of the hearing.

Arbitration Materials

  • Parties are encouraged to establish a briefing schedule for submittal of their arbitration materials. If you are not able to agree on a briefing schedule, please contact our case administrator, Marygrace Aguiling Sacramento,, to schedule a pre-arbitration conference call. Please see the enclosed JdR arbitration rules for guidelines.
  • Your written submittal must include a cover sheet with the date of the arbitration, the case name and the name of the arbitrator.
  • Your submittal may be delivered, faxed or emailed to JdR.
  • If you email arbitration materials, you must email them to our case administrator, Marygrace Aguiling Sacramento,, as well as to the arbitrator, showing a copy to opposing counsel. The arbitrator email addresses are listed below. You should indicate if a hard copy is to follow. Materials over 30 pages in length must be submitted via hard copy, also. You will receive a reply email from JdR confirming receipt. If you do not receive a confirmation email, please call 206-442-1683.
  • In order for written material to be considered by the arbitrator, you must show a copy to opposing counsel so as not to have ex parte contact with the arbitrator.
Charles S. Burdell, Jr.
John P. Erlick
George Finkle
Bruce Heller
Larry A. Jordan
 Paris K. Kallas
Linda Lau
Palmer Robinson
Steve Scott

If you would like your exhibits back after the arbitration, please contact our office before the arbitration to make arrangements to pick them up. In no instance are materials returned to counsel that have been marked up by the arbitrator.

If you have questions please contact the Case Administrator/Arbitration Coordinator:
Marygrace Aguiling Sacramento DD: 206-442-1683

Please visit our Fees page for complete information on rates for Arbitration services.