The Pre-Hearing Stage:
Know your own case and your opponent’s case as best you are able.
Carefully select an arbitrator having knowledge in the area of the dispute.
Carefully screen potential witnesses for maximum credibility.
Develop a theory of your case, all preparation should be guided by it.
Analyze all documents that may be used as exhibits thoroughly.
The Hearing Stage:
The arbitrator is looking for an orientation as to the fundamental issues at the outset of the hearing. The opening statement is a critical tool.
The sequence of the testimony is important.
Consider a witness sequestration request.
Begin with a persuasive witness; end with a dramatic one.