Clause & Stipulation Language
Naming Daniel B. Garrie in your arbitration agreement or stipulation.
Daniel B. Garrie is not on the AAA roster. Under the AAA Commercial Arbitration Rules, parties may designate any qualified neutral by mutual consent, and AAA administers the matter under its Rules. The four-step path below, and the ready-to-adapt language that follows, is how counsel do it.
01 — Selection Process
How parties consent Daniel into AAA matters, and what counsel typically ask.
- Step 01Confirm availabilitySonya Morgan responds within 2 business days · conflicts and fees
- Step 02Joint stipulation to AAAFor pending matters · sample stipulation language below
- Step 03Or a clause in the contractFor new agreements · sample contract language below
- Step 04AAA administers · Daniel arbitratesScheduling, preliminary hearing, and pre-hearing orders proceed
02 — Model Language
Ready-to-adapt language for counsel.
The language below is provided as a starting point only and is not legal advice. Counsel should review and adapt it for the matter and the governing jurisdiction.
Post-dispute stipulation (pending AAA matter)
Adapt to the matter and review with counsel.
The parties hereby stipulate and agree, pursuant to their authority under the AAA Commercial Arbitration Rules, that Daniel B. Garrie shall serve as the [sole arbitrator / chair / party-appointed arbitrator] in this matter, notwithstanding that Mr. Garrie does not appear on the AAA National Roster of Arbitrators. The American Arbitration Association shall administer the arbitration in accordance with its Rules. The parties further stipulate that this designation is mutual, knowing, and voluntary.
Pre-dispute clause (new agreement)
Tailor the qualifications to the subject matter of the contract.
Any dispute, controversy, or claim arising out of or relating to this Agreement, or the breach, termination, or validity thereof, shall be finally resolved by binding arbitration administered by the American Arbitration Association under its Commercial Arbitration Rules. The parties agree that Daniel B. Garrie shall serve as the sole arbitrator. If Mr. Garrie is unavailable or unable to serve, the parties shall agree on a successor arbitrator with substantial experience in [cybersecurity, e-discovery, software, and intellectual property] disputes. The seat of the arbitration shall be [city, state]. The arbitration shall be conducted in English. Judgment on the award may be entered in any court of competent jurisdiction.
03 — Frequently Asked Questions
What counsel ask about naming Daniel in an arbitration.
Why isn't Daniel on the AAA arbitrator roster?+
Daniel is a JAMS Neutral. He also serves on the SIAC panel and is admitted to the LCIA, HKIAC, and CPR. AAA maintains an independent roster, and Daniel is not on it. Under the AAA Commercial Arbitration Rules, however, parties are not confined to the AAA roster — by mutual consent the parties may designate any qualified neutral, and AAA administers the matter under its Rules, subject to its standard disclosure and confirmation process.
How do parties consent Daniel into a pending AAA arbitration?+
Three steps: (1) contact Sonya Morgan to confirm availability, conflicts, and fee schedule (most inquiries resolved within two business days); (2) submit a joint stipulation to AAA naming Daniel as the arbitrator (or as chair / party-appointed arbitrator on a tri-panel); (3) AAA administers the matter in the ordinary course and Daniel proceeds to scheduling, preliminary hearing, and pre-hearing orders.
The path is established. Daniel has been consented in by the parties to sit as the arbitrator in multiple AAA matters within his specialization, and has presided over several AAA-ICDR international arbitrations.
How do we name Daniel in a new contract's arbitration clause?+
Specify Daniel directly in the dispute-resolution clause, or describe the qualifications the parties want in the arbitrator. Either approach functions. Sample language is in the next item.
What is sample stipulation language for a pending AAA matter?+
Adapt to the matter and review with counsel.
The parties hereby stipulate and agree, pursuant to their authority under the AAA Commercial Arbitration Rules, that Daniel B. Garrie shall serve as the [sole arbitrator / chair / party-appointed arbitrator] in this matter, notwithstanding that Mr. Garrie does not appear on the AAA National Roster of Arbitrators. The American Arbitration Association shall administer the arbitration in accordance with its Rules. The parties further stipulate that this designation is mutual, knowing, and voluntary.
What is sample contract-clause language for a new agreement?+
Tailor the qualifications to the subject matter of the contract.
Any dispute, controversy, or claim arising out of or relating to this Agreement, or the breach, termination, or validity thereof, shall be finally resolved by binding arbitration administered by the American Arbitration Association under its Commercial Arbitration Rules. The parties agree that Daniel B. Garrie shall serve as the sole arbitrator. If Mr. Garrie is unavailable or unable to serve, the parties shall agree on a successor arbitrator with substantial experience in [cybersecurity, e-discovery, software, and intellectual property] disputes. The seat of the arbitration shall be [city, state]. The arbitration shall be conducted in English. Judgment on the award may be entered in any court of competent jurisdiction.
How quickly can Sonya confirm availability and clear conflicts?+
Most inquiries are resolved within two business days. Sonya Morgan runs a comprehensive conflicts check against Daniel's matter ledger, confirms his calendar for proposed hearing dates, and shares the engagement materials and fee schedule.
Will Daniel sit as sole arbitrator, party-appointed, or chair?+
All three. Daniel has served in each capacity in the arbitrations he has heard, with current availability for sole-arbitrator, party-appointed, and chair seats in domestic and international matters.
Does Daniel hear AAA-ICDR international matters and other forums?+
Yes. Daniel has heard several AAA-ICDR international arbitrations. He sits as a JAMS Neutral domestically and through JAMS International, serves on the SIAC panel in Singapore, and is admitted to the LCIA (London) and HKIAC (Hong Kong). He is a Distinguished Neutral at the CPR Institute.
What types of disputes does Daniel typically hear?+
Cyber, data-breach, AI-driven disputes, source-code, e-discovery, intellectual property, trade secrets, partnership-dissolution, post-M&A, joint-venture wind-downs, complex commercial, and insurance-coverage matters. See Practice Areas for the full list.
Are the sample stipulation and contract-clause languages legal advice?+
No. The sample language is provided as a starting point only and is not legal advice. Counsel should review and adapt the language for the matter and the governing jurisdiction.
When the parties are ready
Consent Daniel in. Begin with Sonya.
Once both sides have agreed in principle, Sonya Morgan coordinates Daniel's availability, runs the conflicts check, and shares the engagement materials. Most counsel are arbitrator-confirmed within two business days.