Tips on arbitration post-hearing briefs———>

The biggest mistake I see in post-hearing briefs is ignoring their strong points and ignoring your weak points. You know they're going to bring these up. You ignore these at your peril. Bring them up yourself.

I'm going to give you seven pointers:

First — Start your brief with a one-paragraph summary that gives a nutshell of your whole case. One paragraph.

Second — Remember your theme. You developed a theme for the hearing. So I want to see that theme developed throughout the brief.

Third — You're always dealing with rules: a collective bargaining agreement, a statute, government regulation, employer’s past practice. And these rules have elements: the verbs, the nouns, the adjectives.

Fourth — Tease out those elements and tie each one to a fact.
Element+Fact. Element+Fact

Fifth — Use headings to separate out the parts of your brief.

Sixth — If your brief is long, include a table of contents at the beginning, but after your one-paragraph summary.

Seventh — Close your brief by telling the arbitrator exactly what you want the arbitrator to do. Do not leave that to chance.