The Arbitrator (i) shall apply internal laws of the State of New York consistent with the Federal Arbitration Act and applicable statutes of limitations, or, to the extent (if any) that federal law prevails, shall apply the law of the U.S., irrespective of any conflict of law principles; (ii) shall entertain any motion to dismiss, motion to
strike, motion for
judgment on the pleadings, motion for complete or
partial summary judgment, motion for
summary adjudication, or any other dispositive motion consistent with New York or federal rules of procedure, as applicable; (iii) shall honor claims of privilege recognized at law; and (iv) shall have authority to award any form of legal or equitable relief;
Acting for a wide variety of contracting authorities and utilities, as well as bidder clients on procurement challenges and achieving successful outcomes, by way of negotiation,
strike out /
summary judgment and swift
partial re-run (most recently Cemex UK Operations Limited v Network Rail Infrastructure Limited (2017)-RRB-