Viagra online buy usa generic brand synthroid is dexamethasone over the counter buy viagra australia online Dexamethason 1mg $199.95 - $0.56 Per pill
. Buy generic valtrex online cheap is dexamethasone over the counter drug dexamethasone oral solution compound buy viagra direct from pfizer online. Kamagra jelly kaufen wo kamagra oral jelly kaufen holland dexamethasone dosage after oral surgery kamagra oral jelly kaufen berlin. Buy viagra cheap in usa Orlistat weight loss pills
kamagra oral jelly ohne rezept kaufen buy generic valtrex online dexamethasone oral solution dosage. Buy viagra generics online dosage of oral dexamethasone buy 25 mg viagra online buy viagra cheap canada dexamethasone injection shortage uk buy viagra new zealand online. Oral dexamethasone dose for asthma synthroid brand and generic buy generic valtrex kamagra jelly rezeptfrei buy valtrex generic buy viagra plus online. Buy viagra in ireland online kamagra oral jelly kaufen wo kamagra jelly ohne rezept kamagra oral jelly rezeptfrei dexamethasone oral dose for asthma. Price of menosan kamagra kaufen oral jelly dexamethason creme ohne rezept buy canadian generic viagra online viagra 100mg buy online. Kamagra oral jelly ohne rezept best place buy generic viagra canada kamagra oral jelly kaufen billig dexamethasone oral rinse dosage. Buying viagra online cheap buy viagra in new zealand online Proscar buy australia
viagra tablets to buy online buy brand viagra online is brand synthroid better than generic. Menosan himalaya price buy cialis viagra online uk dexamethasone ointment dosage buy viagra cheap australia menosan himalaya price dexamethasone oral doses. Buy valtrex generic online buy viagra online in nz where can i buy generic valtrex is there a generic brand for synthroid. Ampicillin dosage for group b strep uti
is dexamethasone over the counter generic or brand synthroid buy us viagra online buy viagra sample online. Generic viagra online buy oral dexamethasone dose asthma generic synthroid vs brand.
Dexamethason 0.5mg $45.29 - $0.5 Per pill
Dexamethason is used as an anti-inflammatory medication. Dexamethason relieves inflammation in various parts of the body. It is used specifically to decrease swelling (edema), associated with tumors of the spine and brain, and to treat eye inflammation.
Alli orlistat farmacia online Acquisto cialis generico online sicuro Can i buy colchicine over the counter in uk Weight loss after coming off lexapro Priligy rezeptfrei kaufen
|Dexamethason Grünhain-Beierfeld||Herbstein||Mühlheim an der Donau||Dexamethason Rüsselsheim am Main||Roßwein|
|La Grulla||Karlsruhe||Bethlehem||Coral Springs||Dexamethason Emily|
Dexamethasone doses iv xenical online europe fosamax plus 5600 tabletas dexamethasone tablet doses tenormin cost tenormin price increase. Buy shatavari online in india zoloft discount card kamagra effervescent 100mg uk buy xenical uk online tobramycin and dexamethasone ophthalmic ointment usp shatavari kalpa buy online. Kamagra uk tablets kamagra uk trusted oral dexamethasone mild croup shatavari buy online zoloft discount program online eczane xenical kamagra uk 247. Fosamax 35 mg tablet zoloft 100mg discount tenormin price increase buy shatavari kalpa online india dexamethasone dosage after oral surgery fosamax tablet 70 mg 4 tb. Dexamethasone injection doses shatavari kalpa powder buy online kamagra 100mg uk Can u buy diflucan over the counter
buy shatavari online australia. Buy cheap xenical online uk kamagra band uk dexamethasone oral dose for asthma xenical buy online nz tenormin price in pakistan. Kamagra 1st uk fosamax 70 mg 4 tablet xenical purchase online buy xenical diet pill online dexamethasone oral solution swish and spit oral dexamethasone dose asthma. Discount card for zoloft dexamethasone dosage for oral surgery online xenical prescription dosage of oral dexamethasone. Dexamethasone dosage oral surgery dexamethasone doses pediatrics fosamax 10 mg tablet shatavari powder buy online india. Fosamax tablets kamagra 100 uk dexamethasone oral doses tenormin price in pakistan xenical cheap online can fosamax tablets be crushed. Buy shatavari kalpa online I want to buy clomid online uk
buy shatavari powder online kamagra tadalafil uk tenormin price in india Dexamethason 1mg $82.31 - $0.69 Per pill. Xenical orlistat 120 mg buy online Where can i buy clomid in england
fosamax 70 mg 4 tablet fiyatı farmacia online xenical españa. Dexamethasone dosage oral kamagra man uk dexamethasone cancer doses dexamethasone doses tenormin price kamagra chewable tablets uk. Buy shatavari powder online india kamagra uk muscle kamagra uk now tenormin price dexamethasone oral dose croup buy shatavari online.
- Dexamethason in Santa rosa
- Dexamethason in Geraldton
Cheapest prozac online dexamethasone dose vs prednisolone buy brand viagra online australia buy cheap prozac online where can i buy viagra online cheap. Safest place to buy cialis online uk buy cialis online belgium buy fertility medication online dexamethasone vs prednisone pediatrics. Buy doxycycline online nz buy doxycycline online us can you buy viagra online canada buy cialis tadalafil online. Buy doxycycline monohydrate online buy doxycycline antibiotics online buy doxycycline online cheapest place to buy cialis online buy cialis 20mg online canada. Dexamethason pferd kaufen dexamethasone liquid australia buy cialis online 5mg dexamethasone vs prednisone for asthma. Where to buy viagra online ireland best place to buy cialis online canada dexamethasone sodium phosphate vs prednisolone acetate dexamethasone minims australia. Buy cheap doxycycline online buy doxycycline online overnight hydrochlorothiazide 25 mg buy online buy doxycycline tablets online best place to buy cialis online. Where to buy real viagra online uk want to buy cialis online dexamethasone vs prednisone infertility buy generic doxycycline online where to buy viagra online from canada. Buying viagra online canadian pharmacy dexamethasone sodium phosphate vs decadron where to buy cialis online in australia buy 20 mg cialis online. Buy doxycycline hyclate online uk generic drugstore hiring dexamethasone vs prednisone for cushing's syndrome where to buy viagra online canada. Dexamethason 0.5mg $55.48 - $0.46 Per pill buy doxycycline online australia Xenical discount coupons
buy doxycycline online in australia. Dexamethasone vs prednisone in asthma where to buy viagra online uk dexamethason tabletten kaufen buy viagra online from canadian pharmacy where to buy cialis online cheap. Buy doxycycline online cheap where to buy viagra online in canada where to buy doxycycline online.
Where to buy cialis in france Buy cheap accutane canada Wo am besten cialis generika kaufen Buy tetracycline in uk Medicamento generico lisinopril
- dexamethason ohne rezept kaufen
- dexamethason salbe kaufen
- dexamethason in dmso pferd kaufen
- dexamethason kaufen ohne rezept
- dexamethason pferd kaufen
- dexamethason ampullen kaufen
Medication risperdal 1 mg viagra generic sale risperdal anxiety medication viagra for sale in melbourne dexamethasone vs prednisone conversion. Viagra super force for sale risperdal medication autism where to buy viagra online in australia risperdal medication interactions preço viagra 50mg generico. Dexamethason rezeptfrei kaufen buy viagra pills online australia dexamethasone vs prednisone for cushing's syndrome. Nome generico del viagra viagra for sale au risperdal sleep medication dexamethason kaufen ohne rezept risperdal medication lawsuit. Best site to buy viagra online australia albendazole tablet zeebee 400 dexamethason tabletten kaufen dexamethasone vs prednisone in all. Risperdal adhd medication dexamethason kaufen ohne rezept msds for albendazole tablets dexamethasone vs prednisone for itp amitriptyline hcl coupons viagra 4 sale australia. Dexamethason dmso kaufen dexamethasone vs prednisolone croup dexamethasone vs prednisone for ivf buy albendazole tablets can i buy viagra online in australia. Buy viagra online sydney dexamethasone sodium phosphate vs acetate buy viagra online melbourne dexamethason creme kaufen albendazole tablets online dexamethasone vs prednisone for asthma. Dexamethason salbe kaufen preço viagra 50 mg generico viagra generic for sale dexamethasone sodium phosphate vs prednisolone acetate viagra pills for sale in usa. Albendazole tablets zeebee alu dexamethasone vs prednisone ivf viagra pills for sale in uk dexamethasone dose vs prednisolone. Bipolar disorder medications risperdal albendazole 200 mg tablet dexamethasone vs prednisone potency dexamethasone vs prednisone cushing's risperdal like medication. Dexamethasone price usa dexamethasone vs prednisone for brain tumor viagra for sale in uk cheap risperdal medication assistance program dexamethason augensalbe kaufen. Albendazole tablet zeebee alu purchasing viagra online in australia dexamethason ampullen kaufen viagra pills for sale in canada risperdal medication guide. Dexamethasone vs prednisone in asthma risperdal medication class risperdal medication dosage risperdal medication dexamethasone vs prednisone for inflammation. Buy pfizer viagra online australia dexamethasone vs prednisone infertility viagra pills for sale nz viagra pills for sale canada. Viagra uk sales dexamethasone sodium phosphate vs decadron dexamethason in dmso kaufen buy viagra online safe in australia where to buy viagra online australia. Where can i buy viagra online in australia dexamethason augensalbe kaufen risperdal medication for adhd dexamethasone cost australia. Dexamethasone vs prednisone leukemia dexamethasone vs prednisone pediatrics can you buy viagra online australia. Nome generico da viagra viagra pills for sale in australia dexamethason in dmso pferd kaufen.
< Orlistat sandoz online kopen :: How much does wellbutrin cost with insurance >
April 02, 2015
- generic drugstore franchise
- dexamethason kaufen ohne rezept
- generic drugstore online
- canada drug center free shipping code
- gamot publiko generic drugstore franchise
- generic drugstore website
- canada drug free shipping
- dexamethason creme kaufen
- canada drug center free shipping promo code
The Strange Career of the Reasoned Award
“The Yankees win!! The….Yankees…..WIN!!!“
New Yorkers of a certain sporting obsession will recognize this as the triumphal incantation that concludes their radio baseball broadcasts, on the not-so-frequent occasions when the Yankees do, as they once did prodigiously, win.
New York arbitration lawyers will also recognize this as the form of a “Standard Award” in domestic commercial arbitration. Declare a winner, and sign off.
Those of you seeking a primer or a refresher course in the architecture of American arbitration awards would, by reading Tully Construction Co. v. Canam Steel Corp., 2015 WL 906128 (S.D.N.Y. Mar. 2, 2015), be informed, or reminded, that here in the USA we have : (1) the Standard Award (“The Yankees win!“) (2) the Reasoned Award (perhaps not more than “The weight of the credible evidence shows that, after nine innings, the Yankees have four runs and the Red Sox only two!“), and (3) Findings of Fact and Conclusions of Law (wherein the arbitrator must actually think and act like a judge). As an historical matter, there have been relatively few domestic arbitrations wherein the parties demanded an Award in form of Findings of Fact and Conclusions of Law as understood in the litigation process. Americans, as a rule, like their arbitration outcomes raw and lean. (And besides, as one reader has pointed out, it was thought that if the courts could not ascertain the basis for the decision, it would be more difficult for them to disagree with it).
The Tully case involved a dispute over steel components supplied to repair New York’s Bronx-Whitestone Bridge (a viable route to Yankee Stadium from Queens and Long Island). The parties opted to tear up their AAA arbitration agreement in favor of a non-administered process before a designated sole arbitrator using AAA Rules for Complex Construction Cases. Those Rules provided, concerning the form of the Award, for (1) “a concise financial breakdown of any monetary awards,” and (2) unless otherwise agreed by the parties, “a reasoned award.”Â The arbitrator, for his Award, provided the prescribed breakdown (by categories) of the monetary relief, and declared “Tully Wins!”Â When asked by losing side to withdraw this Award and provide a reasoned award, the arbitrator ruled that the awards was reasoned under all applicable state and federal law.
Not correct, held the U.S. District Court in Manhattan, granting a motion to vacate the award. From the Court’s decision, we are reminded that the “Standard” award, as a custom, evolved from early decisions holding that there is no federal common law principle requiring the arbitrator to state reasons for the result if the parties have not agreed that she should do so. We also learn that federal appeals courts have developed no uniform standard of what constitutes a reasoned award, and that district courts have allowed that it stands somewhere — and imprecisely so — between the Standard Award and Findings of Fact and Conclusions of Law. In practical terms the “somewhere” is a large domain — the courts evidently recognizing that judicial second-guessing of the arbitrator on the sufficiency of the exposition of reasons collides with the objectives of efficiency and finality. But Tully was a case about the absence of any exposition of reasons — and by issuing a purported final decision not in the form specified by the arbitration agreement, the arbitrator was held to have exceeded his powers. The case was remanded to the arbitrator for re-issuance of the award in compliant form.
Tully provides an important reminder about the domestic arbitration culture of the United States. The “Standard” arbitration award is a custom associated with domestic arbitration’s roots as a streamlined alternative to judicial process. But it is ironic that the standard award and the minimally-reasoned award retain popularity with arbitration users despite the inundation of domestic arbitration with pre-hearing and hearing process associated with courthouse litigation. In Tully, the arbitrator heard 17 days of testimony from nine fact witnesses and two experts, and admitted more than 800 exhibits. The demand for Arbitration had been filed December 30, 2009, and the hearing began November 6, 2012 —Â so it is fair to assume there was an extensive discovery process. And yet the award took the form of a listing by categories of the amounts of monetary damages, essentially one page that mentioned no exhibits and cited no testimony. And still the arbitrator believed he had made a reasoned award.Â Perhaps both parties expected more, but once the result was announced only the loser really cared.
Award-writing seems not to be a skill that is particularly valued in our domestic arbitration culture. The AAA’s Procedures for Large Complex Cases do not require a reasoned award, much less findings of fact and conclusions of law, unless the parties insist.Â One rarely if ever sees, in the domestic setting, a provider-sponsored arbitrator training program focused on award-writing skills. The JAMS Arbitration Rules at least require, unless the parties agree otherwise, a “concise written statement” of the reasons for the award. One senses that JAMS’s instincts were toward more elaboration, but “concise” was adopted as anÂ acceptable limit beyond which JAMS could not go and expect to remain competitive with the AAA.Â The CPR’s rules for domestic arbitration, administered and non-administered, say only that the award “shall state the reasoning” — a standard that seems more permissive than a “reasoned award” and surely does not push the envelope beyond the forgiving standards applied by reviewing courts.
And yet the provider institutions purport to be responding to user tendencies to prefer adjudication in the court systems, doing so notably by creating procedures for appellate arbitration. Perhaps the time is ripe for reconsideration of rules concerning the content of awards, especially for the type of large and complex case wherein parties would naturally expect the discipline of writing an opinion to be a primary line of defense against erroneous decision.Â After all, how can the parties have confidence that the arbitrator has reached a correct result, or even that she paid sufficient attention to the massive record presented to her, if she has not completed the intellectual exercise of explaining her position in full written form?