Prompt

Arbitration AI prompts for lawyers

19 prompts you can paste straight into HAQQ or any other assistant. Every one is written out in full. Open it, copy it, change the bracketed parts.

• Enforcing an Award From a Unilaterally Appointed ArbitratorMemoEnterpriseResearch / Authorities

  I act for the [claimant / respondent]. Can an award made by an arbitrator appointed unilaterally by one party be enforced in [jurisdiction]? Answer yes or no in the first line, then justify it.
  Address:
  1. The rule on constitution of the tribunal in that jurisdiction's arbitration law, and whether unilateral appointment goes to validity of the award or only to a ground of challenge.
  2. Where this sits under the New York Convention grounds for refusal, and whether the enforcing court reviews it of its own motion or only on the respondent's application.
  3. Whether the objection is lost by participating in the arbitration without protest, and what counts as a timely protest.
  4. The distinction between setting aside at the seat and refusing enforcement elsewhere. An award set aside at the seat and an award merely challenged are not the same case.
  5. The practical route for my client as [claimant / respondent], with deadlines.
  Mandatory rules: cite the article for each ground under both the arbitration statute and the Convention, and keep the two separate rather than merging them. If the answer depends on the seat, ask me for the seat rather than assuming it, and mark any point where courts in that jurisdiction have not settled the question. Quote the operative text of the New York Convention article and the corresponding article of the arbitration statute at the seat wherever the two provisions differ, rather than paraphrasing either one.

• Is a Dispute Board Decision Final and Binding?MemoExpertResearch / Authorities

  Under an engineering contract governed by the law of [jurisdiction] and based on [FIDIC / an amended form], a dispute board has issued a decision. I act for the [employer / contractor].
  Answer:
  1. Is the decision binding, is it final, and what is the practical difference between the two. A binding decision must be complied with at once even if reviewable; a final one is not reviewable at all.
  2. The period for issuing a notice of dissatisfaction, and the consequence of letting it pass.
  3. Whether the parties may go straight to arbitration, and whether passing through the board is a procedural condition of admissibility.
  4. What happens if a party refuses to comply with a binding but non-final decision: can a separate arbitration be brought on the refusal itself.
  5. The effect of the particular conditions where they amend the standard clause, and ask me for the clause text if I have not supplied it.
  Mandatory rules: distinguish what the contract provides from what the governing law provides, because the second can override the first. Cite both the sub-clause and the article for every point, mark any question the governing law has not settled rather than assuming an answer, and do not assume a particular edition of a standard form unless I name it.

• Appointing an Arbitrator by PetitionMemoExpertResearch / Authorities

  Set out the mechanism for appointing an arbitrator by petition under Egyptian law, compared with English law. I act for the party seeking the appointment.
  Facts: arbitration clause [quote it], agreed number of arbitrators [number], the party in default of appointment [details], date of the invitation to appoint [date].
  Deliverables:
  1. The court or body competent to appoint in Egypt, the provision, and the form of the application and its documents.
  2. The period that must elapse before applying to the court, and how it is computed.
  3. Whether the appointment issues as an order on petition or as a judgment inter partes, and what that does to its appealability.
  4. The criteria binding on the court in choosing: independence, impartiality, nationality, expertise.
  5. A comparison table with the English mechanism: body, form, timing, and appealability.
  6. The effect on the arbitration if the appointment is defective, and whether it later vitiates the award.
  Mandatory rules: cite the article of the Egyptian Arbitration Law and the corresponding section of the English legislation for every step, and quote the operative words of the arbitration clause where its wording changes the answer. Where you are not confident of an equivalent in one of the two systems, write "not found" rather than reasoning across by analogy.

• Arbitration Agreement ClauseAgreementAdvancedDraft / Generate

  You are drafting an arbitration clause for a [type of contract], selecting [arbitration institution: ICC/LCIA/SIAC/DIAC/other] as the administering institution.
  
  Facts: the seat of arbitration, the governing law of the underlying contract, the language of the proceedings, and whether the parties want one arbitrator or three.
  
  Deliverables, as one clause with supporting notes:
  1. The arbitration clause itself, naming the institution, the seat, the governing law, the language, and the number of arbitrators.
  2. A note on any procedural rules to add, such as expedited procedure eligibility or a multi-tier requirement to negotiate or mediate before filing.
  3. A short explanation of why the chosen seat and institution fit the contract type, so the client can sanity check the choice.
  
  Mandatory rules: do not state that a specific institutional rule, deadline, or fee schedule applies without citing the exact rule provision, mark it for confirmation against the institution's current rules instead. This is a drafting aid for a qualified lawyer to review, not legal advice.

• Request for ArbitrationMemoExpertDraft / Generate

  You act for [Claimant] against [Respondent], filing with [arbitration institution] under the arbitration clause in [describe contract/dispute].
  Facts: the contract or relationship giving rise to the dispute, the arbitration agreement's seat and rules, and the conduct complained of.
  Draft the Request for Arbitration covering:
  1. The parties, their counsel, and the contact details required by [arbitration institution]'s rules.
  2. A factual summary of the dispute.
  3. The claims asserted, with the contractual clause or legal basis for each.
  4. The relief sought, including any quantified damages.
  5. The seat, language, and applicable rules of the arbitration, per the arbitration agreement.
  6. Proposed arbitrators or the mechanism for their appointment.
  7. Any procedural request, such as consolidation or expedited procedure.
  Mandatory rules: quote the arbitration clause relied on for the tribunal's jurisdiction rather than asserting jurisdiction in general terms. Flag any requirement of [arbitration institution]'s rules on form or filing you cannot confirm, rather than assuming the request is complete.

• Statement of Defense (Arbitration)MemoExpertDraft / Generate

  You act for [Respondent] in [Arbitration Case Reference] and are drafting the Statement of Defense responding to [Claimant's] claims.
  
  Facts: the claims [Claimant's] statement of case sets out, the factual and legal basis for disputing each one, and any counterclaim of [describe] that [Respondent] wants to assert.
  
  Deliverables:
  1. A response to each of [Claimant's] claims in turn, addressing jurisdiction or admissibility objections first if any exist.
  2. The factual defenses to each claim, tied to the specific evidence [Respondent] relies on.
  3. The legal defenses to each claim, tied to the governing law and, where relevant, the contract provisions in dispute.
  4. Any counterclaim of [describe], set out with its own factual and legal basis.
  5. The relief requested, both in response to [Claimant's] claims and in support of any counterclaim.
  
  Mandatory rules: quote the specific contract clause or legal provision a defense relies on, do not paraphrase it and then argue against your own paraphrase. Flag any factual assertion that depends on evidence not yet in the record rather than stating it as established. This is a drafting aid for [Respondent]'s counsel to review before filing, not a substitute for that counsel's judgement.

• Witness Statement (Arbitration)MemoAdvancedDraft / Generate

  You are preparing a witness statement for [Witness Name/Role] in [Arbitration Case Reference], to comply with [IBA Rules on Taking of Evidence/institutional rules].
  Facts: the witness's role, the events within their own knowledge, and the exhibits they will refer to.
  Draft the statement to include:
  1. The witness's identity, position, and relationship to the parties.
  2. Background sufficient to place the witness's evidence in context.
  3. A factual narrative of what the witness observed or did, in chronological order.
  4. Each exhibit referenced, tied to the specific paragraph it supports.
  5. A statement of truth in the form required by [IBA Rules on Taking of Evidence/institutional rules].
  Mandatory rules: include only matters within the witness's own knowledge, and mark anything told to the witness by someone else as hearsay with its source identified. Flag any requirement of [IBA Rules on Taking of Evidence/institutional rules] you cannot confirm rather than assuming the standard form applies.

• Expert Report (Arbitration)ReportExpertDraft / Generate

  You are preparing an outline for [Expert Name], to opine on [subject matter: damages/technical/industry practice] in [Arbitration Case Reference], to comply with [IBA Rules/institutional requirements].
  Facts: the question the expert has been asked to address, the data made available, and any assumption the expert has been instructed to adopt.
  Draft the outline covering:
  1. The expert's qualifications and relevant experience.
  2. The question or instructions the expert was asked to address.
  3. Methodology, including any standard or model applied and why.
  4. Data analyzed, with any assumption clearly separated from that data.
  5. Opinions, each one tied back to the methodology and data that support it.
  6. Compliance with the independence and disclosure requirements of [IBA Rules/institutional requirements].
  Mandatory rules: separate every opinion from the underlying data and assumption it rests on, and mark an assumption as an assumption rather than a verified fact. Flag any data gap that limits the reliability of an opinion rather than presenting the opinion as unqualified.

• Procedural Order DraftMemoAdvancedDraft / Generate

  You are drafting for the tribunal or a party, as instructed, in [Arbitration Case Reference].
  Facts: the procedural stage reached, the number of parties and counsel, and any procedural point already agreed.
  Draft a proposed Procedural Order No. 1 covering:
  1. The procedural timetable, from this order through to the award, with a date for each step.
  2. Document production, including the schedule for requests, objections, and the Redfern Schedule if used.
  3. Witness statements: exchange dates, format, and any limit on length.
  4. Expert reports: exchange dates, format, and any provision for a joint expert.
  5. Hearing logistics: venue, format (in person/virtual/hybrid), and language.
  6. Confidentiality of the proceeding and of documents produced.
  Mandatory rules: state a deadline or procedural default only where it is fixed by the applicable institutional or procedural rules or already agreed by the parties, and flag anything left open for the tribunal to decide rather than filling it in.

• Document Production RequestChecklistAdvancedDraft / Generate

  You act for [Party] in [Arbitration Case Reference].
  Facts: the documents believed to exist, who is thought to hold them, and the factual or legal issue each one bears on.
  Draft document production requests in Redfern Schedule format, with one row per request, covering:
  1. The document or category of documents requested, described narrowly enough to be identifiable.
  2. The issue in the case the document is relevant and material to.
  3. Why the document is not otherwise available to [Party].
  4. A blank column for the opposing party's objection.
  5. A blank column for the tribunal's decision.
  Mandatory rules: tie each request to a specific pleaded issue rather than a general assertion of relevance, and do not request a document category broader than what the stated issue justifies. Flag any request that assumes a fact not yet established in the pleadings. Cite the paragraph of the pleading or witness statement that establishes the issue each request is tied to, and quote the specific allegation being tested.

• Post-Hearing BriefMemoEnterpriseDraft / Generate

  You act for [Party] in [Arbitration Case Reference] and are drafting the post-hearing brief.
  
  Facts: the issues the tribunal identified for the parties to address post-hearing, and the key witness and documentary evidence from the hearing that supports [Party]'s position.
  
  Deliverables:
  1. A summary of the evidence presented at the hearing, organized by issue rather than by witness.
  2. An analysis of the witness testimony, noting where it was tested in cross-examination and how that affects its weight.
  3. An analysis of the applicable law as it bears on each issue the tribunal must decide.
  4. A response to the opposing party's principal arguments, addressed point by point rather than in general terms.
  5. The specific relief requested, tied to the legal basis for each element of it.
  6. A closing section drawing the analysis together into the outcome [Party] is asking the tribunal to reach.
  
  Mandatory rules: cite the transcript page or exhibit number for every factual assertion drawn from the hearing, and cite the specific legal authority for every legal proposition, do not state either as given. Flag any point where the record is ambiguous rather than resolving it in [Party]'s favour by assertion. This is a drafting aid for [Party]'s counsel to review before filing, not a substitute for that counsel's judgement.

• Award Enforcement ApplicationMemoExpertDraft / Generate

  You are drafting an application to enforce [arbitral award] in [jurisdiction] under the New York Convention.
  
  Facts: the seat of the arbitration that produced [arbitral award], the identity and location of assets of the party against whom enforcement is sought, and whether that party has raised any challenge to the award to date.
  
  Deliverables:
  1. The application itself, identifying the award, the parties, and the relief sought.
  2. A list of the supporting documents required, including certified copies of [arbitral award] and the arbitration agreement, with any translation or certification requirements specific to [jurisdiction].
  3. An analysis of how the application satisfies the enforcement requirements under [jurisdiction]'s implementation of the New York Convention.
  4. An anticipatory analysis of the grounds on which the respondent might resist enforcement under Article V, and the response to each.
  5. A note on timing, including any limitation period for bringing the application in [jurisdiction].
  
  Mandatory rules: do not state that [jurisdiction]'s courts have adopted a specific interpretation of a New York Convention ground unless you cite the case or statute it comes from, flag it for local counsel confirmation instead. This is a drafting aid for a qualified lawyer admitted in [jurisdiction] to review, not a substitute for that lawyer's advice.

• Challenge to ArbitratorMemoExpertDraft / Generate

  You are drafting a challenge to [Arbitrator Name] in [Arbitration Case Reference] on the ground of [describe grounds: conflict of interest/lack of impartiality/lack of independence].
  
  Facts: the specific facts giving rise to the challenge, when the challenging party learned of them, and the applicable institutional rules or arbitration law governing challenges.
  
  Deliverables:
  1. A statement of the facts supporting the challenge, in chronological order.
  2. The legal basis for the challenge, citing the specific rule or statutory provision that sets the standard [Arbitrator Name] is alleged to have failed.
  3. An analysis of why those facts meet that standard, rather than merely asserting they do.
  4. The procedural steps and time limit for bringing the challenge under the applicable rules, and confirmation the challenge is timely.
  5. The relief requested, including [Arbitrator Name]'s removal and any consequential relief.
  
  Mandatory rules: cite the specific IBA Guidelines category, institutional rule, or case law relied on for the standard applied, do not assert a standard as settled without naming its source. Flag any fact that the challenging party cannot yet document rather than presenting it as established. This is a drafting aid for counsel to review before filing, not a substitute for that counsel's judgement.

• Emergency Arbitrator ApplicationMemoExpertDraft / Generate

  You are drafting an application for emergency arbitrator relief under [institutional rules], seeking [describe interim measures] before the tribunal is constituted.
  
  Facts: the timeline of events creating the urgency, the harm the applicant faces if relief is not granted, and any steps already taken to put the other party on notice.
  
  Deliverables:
  1. The application itself, identifying the parties, the underlying dispute, and the relief sought.
  2. The case for urgency: why the harm cannot wait for the tribunal to be constituted under the normal timeline in [institutional rules].
  3. The case for irreparable harm: why damages alone would not adequately compensate the applicant.
  4. The case for a prima facie case on the merits, addressed briefly rather than as a full merits brief.
  5. The case for proportionality: why [describe interim measures] goes no further than necessary to protect the applicant.
  6. Confirmation of compliance with the procedural requirements of [institutional rules], including notice to the other party.
  
  Mandatory rules: cite the specific provision of [institutional rules] relied on for each procedural requirement, do not assume a requirement is satisfied without checking it against the rules text. Flag any factual claim of urgency or harm that is not yet supported by evidence rather than asserting it as fact. This is a drafting aid for counsel to review before filing, not a substitute for that counsel's judgement.

• Arbitration Cost SubmissionMemoAdvancedDraft / Generate

  You act for [Party] in [Arbitration Case Reference] and are drafting the costs submission seeking recovery of legal costs and expenses.
  
  Facts: the legal fees, expert fees, and arbitration costs [Party] has incurred, and the cost allocation principles under the applicable institutional rules or the arbitration agreement.
  
  Deliverables, as one submission:
  1. A detailed breakdown of legal fees by phase, case assessment, pleadings, evidence, hearing, and post-hearing, with the supporting invoices referenced rather than restated.
  2. A breakdown of expert fees and other disbursements, similarly referenced to supporting documentation.
  3. A breakdown of arbitration costs, including institution and tribunal fees.
  4. An argument for the cost allocation sought, applying the costs follow the event principle or whatever principle the applicable rules actually set out.
  5. A response to any proportionality or reasonableness objection the tribunal is likely to raise.
  
  Mandatory rules: cite the specific rule or clause that governs cost allocation in this arbitration, do not assume costs follow the event without checking it against the actual rules or agreement. Reference the supporting invoice or timesheet for each figure rather than stating a total without backup.

• Arbitration Clause ComparisonReportAdvancedReview / Redline

  Compare arbitration clauses under the [ICC, LCIA, SIAC, DIFC-LCIA, DIAC] rules for a [type of dispute] seated in [region].
  
  Facts: the contract value or stakes involved (describe), the parties' nationalities (describe), and any existing preference for a seat or institution (state, or none).
  
  Deliverables:
  1. A comparison table across the named institutions: default seat, language of proceedings, number of arbitrators, and appointment method.
  2. Emergency arbitrator provisions: availability, timeline and enforceability of emergency relief.
  3. Expedited procedure thresholds and how each institution's expedited track differs.
  4. Estimated costs: filing fees, administrative fees and arbitrator fees, and how each scales with dispute value.
  5. Enforceability considerations for an award in [region], including relevant New York Convention reservations.
  6. A recommendation of the institution and seat best suited to the stated dispute type, with the reasoning.
  
  Mandatory rules: state a fee, timeline or rule only where it is quoted from the current version of the named institution's rules, where the rules have changed or you are unsure of the current text, flag it rather than stating a figure.

• Hearing Transcript Digest by IssueMemoAdvancedSummarize / Extract

  Act as counsel for [OUR SIDE]. Digest the hearing transcript below by issue rather than by witness. For each issue in [list the issues in dispute], pull the testimony that supports our position, the testimony that supports the other side, and any admission against interest, each cited to a page:line reference. Do not characterize any testimony you cannot point to a specific page:line for. Flag any issue where the transcript is thin or silent, so we know where the post-hearing brief needs to lean on documentary evidence instead. Transcript: [PASTE]. Issues: [LIST].

• GCC Cross-Border Dispute Resolution Clause Audit: Seat, Venue and EnforceabilityReportEnterpriseReview / Redline

  Act as arbitration counsel auditing the dispute-resolution provisions of [AGREEMENT] in a cross-border transaction between [PARTY A, jurisdiction] and [PARTY B, jurisdiction], performed in [COUNTRY], with the counterparty's assets likely located in [ENFORCEMENT JURISDICTIONS]. Scope: the clauses pasted below only. Cite the rule, article or institutional provision behind each conclusion; where you cannot cite it, mark it To Be Confirmed rather than asserting it. Return: (1) Clause Anatomy: what the clause actually provides: governing law of the contract, legal seat, hearing venue, institution and rules, number and method of appointment of arbitrators, language of the proceedings, and any tiered pre-conditions such as negotiation or mediation; (2) Seat versus Venue Diagnosis, whether the drafting confuses the legal seat with the hearing venue, which curial law that leaves supervising the arbitration, which courts would hear a challenge, and the exact replacement wording; (3) Language of Proceedings, whether it is specified, what applies by default if it is not, and the practical consequence where evidence exists in both Arabic and English (translation cost, bilingual tribunal, the evidentiary record); (4) Pathology Check, asymmetric or optional clauses, floating or unspecified seat, a named institution paired with another body's rules, an institution that no longer exists under that name, unworkable time limits, and conflicts with the jurisdiction or governing-law clauses elsewhere in the agreement; (5) Enforcement Path: for each of [ENFORCEMENT JURISDICTIONS], the recognition route and the formalities to confirm, including whether the local court requires an Arabic translation of the award and of the arbitration agreement; (6) Arbitrability and Authority, subject matter that may not be arbitrable locally, and local requirements on who has authority to bind a company to arbitration, flagged for confirmation; (7) Redraft, a clean replacement clause, with an Arabic counterpart if the agreement is bilingual; (8) Residual Risks and Local Counsel Questions. Clauses: [PASTE].

• Enforcing a Foreign Judgment in a MENA StateMemoEnterpriseResearch / Authorities

  Act as enforcement counsel advising [CREDITOR] on enforcing a judgment obtained from [ORIGINATING COURT AND COUNTRY] on [DATE] for [AMOUNT AND RELIEF] against [DEBTOR] whose assets are in [TARGET COUNTRY]. Known facts: [WHETHER THE DEBTOR APPEARED, HOW SERVICE WAS EFFECTED, WHETHER ANY APPEAL REMAINS, WHAT ASSETS ARE KNOWN AND WHERE]. This is a foreign court judgment, not an arbitral award. The routes are different and the treaty framework is different, so start by identifying which instrument, if any, connects these two states, and whether the target country instead requires proof of reciprocity. Do not assert a treaty status, a reservation or a limitation period you cannot attribute to a named source; mark it To Be Confirmed for local counsel. Return: (1) Route Options: the bilateral treaty, regional convention or domestic reciprocity route available, each with what it requires and how long it takes, and a clear statement where none applies and the claim must be brought afresh; (2) Threshold Conditions, jurisdiction of the originating court as the target court would assess it, proper service, finality, absence of a conflicting local judgment, and reciprocity where required, each with the evidence that proves it; (3) Public Policy Screen, the elements of the judgment most likely to be refused locally (interest awards, punitive or multiple damages, costs orders, relief unknown to the local system, matters reserved to local courts), and whether partial enforcement of the rest is possible; (4) Document Pack, certified copy, certificate of finality, proof of service, translation by a licensed translator, and the legalisation or apostille chain, with who issues each and in what order; (5) Procedure: the court or execution department that hears it, the form of application, whether the merits can be reopened, the debtor's likely defences, and the appeal route; (6) Asset Recovery Plan, attachment, travel bans where available, bank and registry searches, and what can be secured before the debtor is on notice; (7) Timing and Cost, a realistic range with the assumptions behind it, and the limitation period to confirm; (8) Alternative Strategy, where enforcement looks weak, whether re-litigating locally, enforcing in a third country, or settling is the better route, with the reason. This is a strategy aid for a qualified local practitioner, not legal advice.

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