Introduction: Same Hypothetical but New York Article 75 Changes the Timing Analysis
New York’s arbitration statute is New York Civ. Prac. L. & R. (“CPLR”) Article 75. It is essentially New York’s version of the Federal Arbitration Act (“FAA”). The FAA was modeled on the statutory predecessor of Article 75. That said, Article 75 and the FAA differ in some material respects.
Our recent Arbitration Law Forum article (the “FAA No Agreement Article”) addressed whether, under the FAA, a business that never agreed to arbitrate may oppose confirmation of an adverse default award even though it did not serve within FAA Section 12’s three-month limitation period a timely motion to vacate, modify, or correct the award.
How would Article 75 resolve the question posed in the FAA No Agreement Article? As we’ll see, the ultimate outcome under both statutes is similar but there are some materially different timing and procedural rules in play. This post discusses how and why that is so.
The Article 75 Hypothetical
Suppose the applicable arbitration law is not the FAA, but New York’s CPLR Article 75. Assume that the claimant properly serves an ordinary demand for arbitration or a notice of intention to arbitrate that meets the requirements of CPLR 7503(c), except that the parties have not agreed to arbitrate, and there is no state contract law basis for binding the respondent party to arbitrate as a nonsignatory.
The business does not participate in the demanded arbitration and objects in writing on the ground no arbitration agreement exists. The arbitration proceeds, the arbitrator makes an adverse default award; more than 90 days pass after delivery of the award; the business does not make a timely CPLR 7511(a) motion to vacate, modify, or correct; and the award winner then moves to confirm. The business appears and opposes confirmation on one ground only: no arbitration agreement was ever made, and there is no state law basis on which the business could be bound to arbitrate as a nonsignatory or otherwise.
Can the business still obtain a judicial determination of the threshold issue of whether the parties agreed to arbitrate in the first place? The better answer is yes, if the defense is a genuine Matter of Matarasso (Continental Casualty Co.) “no agreement” defense and not an ordinary arbitrability or vacatur objection that questions the validity, enforceability, or scope of an arbitration agreement, not the existence vel non of that agreement. But care and caution is advisable because CPLR 7503(c), 7510, and 7511 point strongly toward preclusion in other cases. The New York Court of Appeals’ narrow Matarasso exception governs: the dispute must concern the existence of the arbitration agreement, and nothing else. See Matter of Matarasso (Continental Cas. Co.), 56 N.Y.2d 264, 266-68 (1982).
There is yet another important twist. At least where the FAA does not apply, New York’s 90-day deadline for an affirmative CPLR 7511(a) vacatur application is not necessarily the end of the road when the award winner later seeks confirmation, and the loser seeks to vacate on a ground other than arbitration agreement non-existence. At least the First and Second Departments hold, contrary to the FAA Florasynth rule, that a party may raise CPLR 7511 objections defensively in opposition to a timely confirmation application even after elapse of the 90-day limitation period. Matter of Pine St. Assocs., L.P. v. Southridge Partners, L.P., 107 A.D.3d 95, 100 (1st Dep’t 2013); Jurcec v. Moloney, 164 A.D.3d 1431, 1432 (2d Dep’t 2018). So, unlike the FAA Florasynth scenario discussed in our prior post, the more vexing New York problem is usually the missed 20-day deadline under CPLR 7503(c), not simply the passage of 90 days after the award.
This article addresses New York arbitration law only. It assumes that CPLR Article 75 supplies the relevant post-award procedural rules and that those rules are not displaced by the FAA or another governing arbitration regime. Whether the FAA governs or preempts a particular state-law procedural rule can require a separate analysis outside the scope of this post.
New York Article 75: Two Different Timing Rules
Article 75 20-Day Rule: CPLR 7503(c)
CPLR 7503(c) provides a person served with a proper demand for arbitration or notice of intention to arbitrate only a very brief period within which to seek judicial intervention. The notice must specify the agreement pursuant to which arbitration is sought, supply the required identifying information, and advise that unless the recipient applies to the court for a stay arbitration within 20 days, the recipient “shall thereafter be precluded from objecting that a valid agreement was not made or has not been complied with and from asserting in court the bar of a limitation of time.” CPLR 7503(c).
The Court of Appeals has repeatedly treated that 20-day period as strict when an arbitration agreement exists. Aetna Life & Casualty Co. v. Stekardis, 34 N.Y.2d 182, 185-86 (1974); Matter of Fiveco, Inc. v. Haber, 11 N.Y.3d 140, 144-45 (2008). If a CPLR 7503(c)-compliant notice of intention to arbitrate is properly served—or if the party challenging the award participated in the arbitration—and the objection concerns validity, enforceability, contractual compliance, scope, or statute of limitations, it must be made by a timely application for a stay as contemplated by CPLR 7503(c). See CPLR 7503(b) & (c); CPLR 7511(b)(2)(i)-(iv).
The 90-Day Rule: CPLR 7511(a)
For its part, CPLR 7511(a) provides that an application to vacate or modify an award may be made within 90 days after delivery. That sounds like a hard post-award cutoff. But New York law distinguishes an affirmative application to vacate from a defense asserted when the award winner asks for confirmation.
The First Department has stated that a party may challenge an award either by moving under CPLR 7511(a) within 90 days or by objecting to the award in opposition to a later confirmation application notwithstanding expiration of the 90-day period. Pine Street, 107 A.D.3d at 100. The Second Department says the same thing. Jurcec, 164 A.D.3d at 1432. A recent Appellate Term decision applied that rule to a default award: although the respondent’s cross-motion to vacate was untimely, the court treated the supporting affidavit as opposition to confirmation and considered the asserted CPLR 7511 ground. Slomin’s, Inc. v. Kyprianides, 2024 N.Y. Slip Op. 51539(U), at *2 (App. Term 2d Dep’t Sept. 27, 2024).
For businesspersons, the practical point is important: missing the 90 days is generally not the recommended course, but under New York law it does not necessarily mean that every objection disappears when the prevailing party later moves to confirm. By contrast, ignoring a proper CPLR 7503(c) demand can cause the loss of arbitrability objections before the arbitration even begins.
Matarasso: Under CPLR Article 75 an Arbitration Notice Cannot Create an Arbitration Agreement That Never Existed
Matarasso is the starting point because its facts eliminated an easy escape route: the Court of Appeals expressly noted that the insurer had been served with a proper notice of intention to arbitrate and did not seek a stay until roughly 60 days later. 56 N.Y.2d at 266-67. The claimant argued that CPLR 7503(c)’s 20-day rule therefore ended the inquiry. The Court of Appeals said no.
The Court held that an untimely stay application may be entertained where its basis is that the parties “never agreed to arbitrate,” as distinguished from a case in which an arbitration agreement exists but is claimed to be invalid, unenforceable, unfulfilled, or inapplicable. Id. at 266. CPLR 7503(c) speaks in terms of “parties,” naturally referring to parties to an arbitration agreement, and the Legislature could not be understood to have intended that a person become bound to arbitration merely by remaining inactive for 20 days where “no agreement to arbitrate has ever been made.” Id. at 267.
The Court of Appeals reaffirmed Matarasso in Fiveco, 11 N.Y.3d at 144-45. Recent decisions spanning all four Appellate Divisions continue to recognize the narrow exception Matarasso carved. See Matter of Government Employees Insurance Co. v. De Liriano, 237 A.D.3d 613, 613 (1st Dep’t 2025); Matter of Continental Casualty Co. v. Anderson, 245 A.D.3d 935, 936 (2d Dep’t 2026); Matter of Klein (Human Care Services for Families & Children, Inc.), 250 A.D.3d 1316 (3d Dep’t 2026); Matter of Allstate Insurance Co. (Cappadonia), 143 A.D.3d 1266, 1267 (4th Dep’t 2016).
The recurring lesson is that the exception is about the absence of any arbitration commitment, not about whether an existing arbitration agreement should be enforced, invalidated, or construed in the way the challenger prefers.
Why the Matarasso Defense Should Carry Through to Confirmation
The Court of Appeals has not, in a fact pattern identical to our hypothetical, expressly held that a properly served, nonparticipating respondent may wait until a motion to confirm is served and then invoke Matarasso after both the 20-day and 90-day periods have passed. The better reading of Article 75 and existing case law nevertheless supports that result in a genuine no-agreement case.
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The Matarasso rationale is not about forgiving a late filing
Matarasso did not create an equitable extension of the 20-day period. It held that the statutory preclusion rule does not operate in the first place where no agreement to arbitrate exists. 56 N.Y.2d at 267. If 20 days of inaction cannot manufacture assent to arbitration, the same inaction should not create it post award in circumstances where the arbitrator proceeded and made an award ex parte.
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Article 75 makes a written arbitration agreement a sine qua non for confirmation
CPLR 7501 begins with a “written agreement” to arbitrate and provides that such an agreement “confers jurisdiction on the courts of the state to enforce it and to enter judgment on an award.” CPLR 7514(b) reinforces the point by requiring the judgment roll to “consist of[,]” among other things, “the original or a copy of the [arbitration] agreement. . . .” CPLR 7514(b).
Those provisions make the agreement a threshold statutory predicate for using Article 75’s summary enforcement machinery against the person to be bound.
MBNA America Bank, N.A. v. Straub, a post-award confirmation decision, reasoned that a court must have the written arbitration agreement before it and must establish its binding nature. 12 Misc. 3d 963, 965-68 (Civ. Ct. N.Y. Co. 2006). Its footnote 5 explains that use of CPLR 7503(c)’s notice procedure does not bar an argument that no arbitration commitment exists, so long as the objector did not participate. Id. at 969 n.5. Cach, LLC v. Viscuso likewise declined to treat service of an arbitration notice as conclusive where a nonparticipating respondent appeared at the confirmation hearing and disputed that the agreement bound him individually. 2009 N.Y. Slip Op. 32031(U), at *3-4 (Sup. Ct. Nassau Co. Aug. 18, 2009).
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CPLR 7511(b)(2) and Case Law Suggests the No Agreement Principle Should Apply Post Award Even if the Challenger is Served with a Notice of Intent to Arbitrate and does not Move for a Stay
CPLR 7511(b)(2) provides that that the no agreement principle applies in the post-award context in situations where the challenging party was not served with a notice of intention of arbitrate and did not participate in the arbitration. It states:
The award shall be vacated on the application of a party who neither participated in the arbitration nor was served with a notice of intention to arbitrate if the court finds that:
(i) the rights of that party were prejudiced by one of the grounds specified in paragraph one [i.e., ordinary vacatur grounds, not no agreement grounds]; or
(ii) a valid agreement to arbitrate was not made; or
(iii) the agreement to arbitrate had not been complied with; or
(iv) the arbitrated claim was barred by limitation under subdivision (b) of section 7502.
CPLR 7511(b)(2).
CPLR 7511(b)(2) raises the question whether a no agreement objection to confirmation, and in support of CPLR 7511(b)(2)(ii) vacatur, would be valid post award, despite the challenger’s failure to move for a stay pre-award in response to a notice of intent to arbitrate. As we’ve seen, Matarasso and Article 75 suggest an affirmative answer.
In light of Matarasso, CPLR 7511(b)(2) can be interpreted to support a post-award no agreement argument as a defense to confirmation, and a basis for a CPLR 7511(b)(2) vacatur, even where: (a) the challenger did not move within 20 days for a stay in response to a notice of intent to arbitrate; and (b) the arbitrator made an ex parte default award.
CPLR 7511(b)(2)’s predicate is “the application of a party who neither participated in the arbitration nor was served with a notice of intention to arbitrate. . . .” Such a person can move to vacate on the ground, among others, that there was no arbitration agreement between the parties. See CPLR 7511(b)(2).
Under Matarasso, however, CPLR 7503(c)’s 20-day “rule barring judicial intrusion into the arbitral process operates only when an agreement to arbitrate exists.” 56 N.Y.2d at 267. The Court found “[s]upport for this view” in CPLR 7503(c)’s text, which “speaks in terms of ‘parties’ (e.g., ‘A party may serve upon another party’), the natural connotation being that the statute is directed toward parties to an agreement to arbitrate.” 257 N.Y.2d at 267.
The reference to the service of a “notice of intention to arbitrate” in CPRL 7511(b)(2) must, as a matter of logic and statutory construction, be to a CPLR 7503(c) notice of intention to arbitrate. One can therefore legitimately argue that under CPLR 7511(b)(2) a party has not been “served with a notice of intention to arbitrate” if the notice expresses an intention to arbitrate in a situation where the parties never agreed to arbitrate and are not otherwise bound by an arbitration agreement under applicable state contract law. And if a person has not been served with a notice of intention to arbitrate, and did not participate in the arbitration, then it can unquestionably assert the non-existence of an arbitration agreement as a ground for vacatur or a defense to confirmation. See CPLR 7511(b)(2).
The Second Department’s decision in Matter of Fiduciary Insurance Co. v. American Bankers Insurance Co. of Florida, 132 A.D.3d 40 (2d Dep’t 2015), further supports the argument. American Bankers arose from a statutory mandatory arbitration rather than an ordinary consensual commercial arbitration, so it is not a perfect match. The no agreement argument was raised for the first time post award and the respondent did not participate. The Court explained that the challenger’s failure to seek a CPLR 7503 stay did not render the dispute arbitrable where “no agreement to arbitrate was ever made.” Id. at 45-46 (citing Matter of Commerce & Industry Insurance Co. v. Nester, 90 N.Y.2d 255, 262 (1997), and Matarasso).
The Most Important Qualification: “I Did Not Sign” Does Not Necessarily Mean “No Agreement” under Article 75
This is where the New York analysis becomes considerably more demanding than a simple nonsignatory test. A straightforward Matarasso case is a true stranger-to-the-arbitration-agreement scenario: no signature, no assent, no incorporation by reference, no agency, no assumption, no third-party-beneficiary theory, no estoppel, no alter-ego basis, no other state-law doctrine binding the business, and no prior judicial order determining that it must arbitrate.
But Matarasso itself cautions that nonsignatory status is not always enough. The Court distinguished Matter of Lane (Abel-Bey), 50 N.Y.2d 864 (1980). In that case there was an arbitration agreement among the corporation’s shareholders but the corporation, though named a party, did not execute the agreement. The question was whether the corporation was bound by that existing agreement could not be considered on an untimely stay motion. See Matarasso, 56 N.Y.2d at 267-68 n.; Lane, 50 N.Y.2d at 865-66
The First Department made the same distinction in Matter of Arbitration of Woodcrest Fabrics, Inc., 98 A.D.2d 52 (1st Dep’t 1983). There, the parties had reached a commercial agreement reflected in an unsigned sales contract containing an arbitration agreement. The court held that the challenger’s contention concerned the validity or enforceability of that arbitration provision, not the complete absence of an agreement, and the missed 20-day deadline was fatal. Id. at 54-56.
A more recent warning is Matter of Kucker Marino Winiarsky & Bittens, LLC v. Neiman, 226 A.D.3d 480 (1st Dep’t 2024). The individual contended that he signed a retainer only as agent for a company and that the arbitration clause was between the law firm and the company. But the agreement provided that the firm “would have ‘a claim’ against any director, officer, or member of the company if the legal fees were not timely paid by the company.” He did not appear in the arbitration and also defaulted on the confirmation proceeding. When he later sought to vacate the judgment, the First Department held, among other things, that by failing to seek a stay he had waived the argument that an agreement requiring him to arbitrate was lacking. Id. at 481-82. The procedural posture was much worse than our hypothetical because he also defaulted at confirmation, but the case demonstrates why a business should not assume that the word “nonsignatory” automatically invokes Matarasso.
On the other side of the line are cases in which the claimant is genuinely outside the contractual relationship. For example, the First Department in De Liriano and the Second Department in Anderson treated the question whether a claimant was an “insured” covered by an insurance policy’s arbitration commitment as a true no agreement issue that survived the 20-day period. 237 A.D.3d at 613; 245 A.D.3d at 936.
What Is Not a True Matarasso No Agreement Defense?
Several common objections do not fall within the exception, which requires the nonexistence of an agreement and no other state-law-imposed contract obligation.
An existing contract allegedly expired or ceased to be enforceable
In Fiveco, the contracts contained arbitration clauses and the challenger alleged the contracts had expired. That was an attack on the present viability of existing agreements, not proof that the parties never agreed to arbitrate. 11 N.Y.3d at 144-45.
A contractual coverage or condition-precedent dispute
Where the policy concededly contains an arbitration clause, a contention that coverage conditions were not satisfied ordinarily concerns compliance with the contract, not the existence of the arbitration agreement. Matter of Steck (State Farm Insurance Co.), 89 N.Y.2d 1082, 1084 (1996); Cappadonia, 143 A.D.3d at 1267.
A scope objection
A party cannot avoid CPLR 7503(c) merely by saying, “We never agreed to arbitrate this particular claim,” when the real issue is whether an existing arbitration clause covers the claim. Matter of Colonial Cooperative Insurance Co., 46 A.D.3d 1012, 1013-14 (3d Dep’t 2007).
Does a Written Pre-Arbitration Objection Preserve the Defense under Article 75?
A prompt written objection is useful, but it should not be confused with a properly made CPLR-7503(c)-compliant stay application. For ordinary arbitrability objections, the statute requires resort to court within 20 days after proper service; a letter to the claimant or arbitration administrator does not replace that step.
For a genuine Matarasso defense, however, the written objection helps demonstrate that the business did not assent by conduct and consistently treated itself as outside the arbitration relationship. It also can help establish nonparticipation. In Matter of Blamowski, the Court of Appeals held that repeated letters to the AAA stating that the employer believed it was not obligated to arbitrate did not transform its refusal to participate into participation. 91 N.Y.2d 190, 195-96 (1997). Blamowski involved a defective CPLR 7503(c) notice, so its ultimate vacatur holding is not our hypothetical, but its treatment of nonparticipation is instructive.
If the notice itself is defective – for example, it omits the statutory 20-day warning – the analysis becomes substantially easier for a nonparticipant. Blamowski held that such a person was not properly “served with a notice of intention to arbitrate” for purposes of CPLR 7511(b)(2), allowing the broader post-award grounds specified there. 91 N.Y.2d at 194-96; see also Albert Bialek Associates Inc. v. Northwest-Atlantic Partners, Inc., 251 A.D.2d 145, 145-46 (1st Dep’t 1998). Our hypothetical deliberately assumes a procedurally compliant notice, so that escape route is unavailable.
Participation Creates a Separate and Potentially Serious Article 75 Risk
The hypothetical also assumes complete nonparticipation. New York law can treat participation as a waiver of the right to obtain a later judicial determination of arbitrability when the participant failed to pursue available judicial remedies. Matter of Commerce & Industry Insurance Co. v. Nester, 90 N.Y.2d 255, 262-64 (1997).
A strict reservation of rights therefore does not necessarily make participation safe. The better practice, when feasible, is to seek judicial relief and preserve appellate or stay remedies before proceeding on the merits. The Third Department’s recent Klein decision illustrates the safer sequence: after an order compelling arbitration, the respondent sought a stay from the appellate court before participating; the court held that the respondent had not waived judicial review of arbitrability. 250 A.D.3d 1316.
For a business that intends to rely on the narrow no agreement defense, abstention remains the cleanest version of the hypothetical. Participation may create arguments about implied assent, waiver, estoppel, or acceptance of the arbitral forum that do not exist when the business consistently refuses to arbitrate.
What Happens If the Confirmation Court Finds That the Business Was Bound to Arbitrate?
This is one of the—if not the—most serious risk posed in the no agreement scenario. The company may be convinced that it is a stranger to the arbitration agreement, yet the confirmation court may find otherwise—for example, because the company assumed the contract, acted through an agent, knowingly accepted contractual benefits, is an intended third-party beneficiary, is estopped under governing state law, or is otherwise bound.
If the court finds an arbitration agreement binds the business, the premise for the Matarasso exception collapses. CPLR 7503(c)’s preclusion rule then becomes formidable. The business ordinarily cannot revive the arguments it might have raised in a stay application made within the 20-day period. Fiveco, 11 N.Y.3d at 144-45; Steck, 89 N.Y.2d at 1084; Woodcrest Fabrics, 98 A.D.2d at 54-56.
But the consequences of missing the 90-day period are not identical to the federal consequences discussed in our prior FAA article. If the award winner moves to confirm and the business timely appears in that confirmation proceeding, Pine Street and Jurcec indicate that otherwise available CPLR 7511(b)(1) grounds can still be raised defensively despite expiration of 90 days. That does not make those grounds easy to prove, and it does not resurrect arbitrability objections already forfeited under CPLR 7503(c). It simply means that the New York 90-day rule should not be confused with the FAA Section 12 rule discussed in our prior post.
The business also must actually appear at confirmation. Kucker Marino illustrates the danger of defaulting twice – first in arbitration and then in the confirmation proceeding – and later trying to undo a judgment. 226 A.D.3d at 481-82. The defensive route recognized in Pine Street and Jurcec assumes that the respondent timely opposes the application to confirm.
Practical Takeaways for Businesspersons
- Treat a CPLR 7503(c) demand as an emergency. Even if management believes there is no arbitration agreement, have arbitration-law counsel analyze the demand immediately and calendar and comply with the 20-day period. Matarasso provides a safety-valve exception, not a preferred litigation strategy.
- Separate “no agreement” from “no signature.” The key question is not simply whether your business signed the paper. Counsel must determine whether an existing arbitration agreement can bind the business through contract, agency, assumption, estoppel, corporate, or other generally applicable principles.
- If the business will not participate, make the position unmistakable. A prompt written objection should state that the business has not agreed and does not agree to arbitrate, is not required to submit to arbitration of any issues, does not voluntarily submit such issues, and will not participate in any purported arbitration proceeding. That letter does not substitute for a stay application where one is required, but it can build a helpful record if carefully drafted protect the factual record.
- Do not assume that 90 days means “nothing can be done.” Under First- and Second-Department authority, at least in a case where the FAA does not apply, or the parties have clearly and unmistakably selected New York arbitration law to govern and supersede all procedural and substantive provisions of the FAA, respondent may raise vacatur objections defensively when opposing a confirmation application after 90 days. The precise available grounds still depend on CPLR 7503, CPLR 7511, the parties’ conduct, and the facts.
- Never default on the confirmation proceeding. A business that wants a court to decide whether it ever agreed to arbitrate must actually present that issue when confirmation is sought. Waiting until judgment has been entered creates an entirely different and much more difficult problem.
Conclusion
Under the strongest version of the hypothetical—a fully compliant CPLR 7503(c) notice, no stay application within 20 days, no participation, an adverse default award, the elapse of more than 90 days after delivery, and a timely opposition to confirmation asserting only that no arbitration agreement ever bound the business (as a signatory or otherwise)—New York law provides a substantial basis for judicial consideration of the no agreement defense.
The argument rests principally on Matarasso: CPLR 7503(c)’s preclusion rule operates only when an arbitration agreement exists and cannot manufacture consent from 20 days of silence. CPLR 7501 and 7514 reinforce the threshold importance of a written arbitration agreement, while post-award cases such as Straub, Cach, and, in a different statutory-arbitration setting, Fiduciary Insurance, support judicial scrutiny of that premise at the enforcement stage. Separately, Pine Street and Jurcec show that expiration of the 90-day CPLR 7511(a) period does not necessarily prevent a respondent from asserting vacatur objections defensively against confirmation.
But the defense is narrower than the phrase “nonsignatory” suggests. Matarasso’s discussion of Lane, Woodcrest Fabrics, Fiveco, and the recent Kucker Marino decision all demonstrate that a court may characterize the dispute as one about whether an existing arbitration agreement binds the challenger, rather than one in which no arbitration agreement ever existed. If the court makes that finding, the missed 20-day deadline can be decisive.
The business lesson is therefore the same one that runs throughout award-challenge practice: timing rules and characterization of the legal issue are extremely important. A true no agreement defense may survive deadlines that would defeat ordinary objections, but it is far safer to identify and litigate the issue promptly than to rely on an exception after an adverse award has already been made.
This article is for general informational purposes and, like all other Arbitration Law Forum articles, is not legal advice. It also does not purport to be an exhaustive recitation of all applicable or potentially applicable law that may bear on the issues discussed. In any event, the applicable law and deadlines, and their interpretation and scope, depend on the agreement, award, forum, and the facts, and are subject to judicial or other decision-maker interpretation.
Contacting the Author
If you have any questions about this article, arbitration, arbitration law, or arbitration-related litigation, then you may contact the author, Philip J. Loree Jr. at (516) 941-6094 or PJL1@LoreeLawFirm.com.
Philip J. Loree Jr. is principal of the Loree Law Firm, a New York attorney who focuses his practice on arbitration and associated litigation. A former BigLaw partner, he has more than 35 years of experience representing a wide variety of domestic and international corporate, other entity, and individual clients in trial-court and appellate matters arising under the Federal Arbitration Act—including matters arising under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards. He also has significant experience arbitrating and litigating insurance- and reinsurance-related and other commercial disputes, and in advising clients and co-counsel in arbitration-law-related matters.
ATTORNEY ADVERTISING NOTICE: Prior results do not guarantee a similar outcome.
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Tags: 20-day deadline, 90-day deadline, Agreement to Arbitrate, arbitration award confirmation, arbitration consent, CPLR 7503, CPLR 7510, CPLR 7511, default arbitration award, Fiveco v. Haber, Matarasso, New York Arbitration Law, no agreement to arbitrate, nonsignatory arbitration, oppose confirmation, Pine Street
