Today, in some of the most pro-arbitration jurisdictions, the number of cases referring to Convention is scarce precisely because the ordinary
rules governing the recognition and enforcement of
awards are more
liberal and, in accordance with article VII (1), routinely applied without any need to refer to the Convention.6
Notwithstanding the
liberal «relation back» principles of the Federal
Rules of Civil Procedure, and despite the plaintiffs» claim of «fraudulent concealment,» the Appellate Practice Group secured an
award of summary judgment in favor of all additional defendants based on the statute of limitations defense.