The Authority of a Decision. The Efficiency of Private Process.
Henning arbitrators deliver rigorous, binding awards in a fraction of the time and cost of litigation. Nationally recognized. Locally trusted for over 30 years.
Submit your Demand for Arbitration through our guided online intake, the fastest path to a case number and assigned coordinator.
You can also initiate an arbitration by email: send your Notice to
arbitration@henningmediation.com,
including the arbitration agreement, party contacts, dispute summary, and relief sought.
Have these ready
Case caption and parties' contact information
Arbitration agreement or court order compelling arbitration
Brief description of the dispute and relief sought
From demand to final award. Click each stage for detail.
01
Demand & Response
The claimant files a Demand for Arbitration stating the nature of the dispute, the relief sought, and identifying the contract, court order, or agreement referring them to arbitration. A case coordinator confirms receipt within one business day and issues the $1,500 initial case deposit invoice, paid per party and applied against fees and expenses as they are incurred, with any unused balance refunded. The respondent tenders its own deposit and files a Response, typically within 20 days of Henning's Notice of Acceptance.
Henning's published rules govern arbitrations administered by our office
unless the parties' agreement specifies otherwise. The current rules took
effect February 6, 2020 and are designed for expeditious case
management, focused discovery, and awards enforceable under the Federal
Arbitration Act.
Full Document
The complete Henning Rules of Arbitration, governing scope, commencement,
constitution of the tribunal, conduct of proceedings, awards, and the
administration of fees.
A plain-language summary of each rule. The full text of the Rules of
Arbitration controls in the event of any conflict.
Rule 01Scope and Application
These rules govern arbitrations administered by Henning. The parties' agreement may modify the rules, except the parties' obligations for Henning's fees. Once seated, the Tribunal interprets and applies the rules and may extend deadlines or sanction non-compliance. Parties may proceed pro se or through counsel in good standing.
Rule 02Commencement of the Arbitration
The Claimant initiates by filing a Demand for Arbitration with Henning, attaching the arbitration agreement (or court order), party contacts, a description of the dispute and relief sought, and the Initial Case Deposit. The Commencement Date is the date Henning gives Notice of Acceptance. The Respondent has twenty days from Acceptance to tender its deposit, file any response, assert affirmative defenses and counterclaims, identify any joined parties, and raise any jurisdictional challenge.
Rule 03Number, Qualification, and Appointment of the Tribunal
Henning maintains the panel of qualified neutrals. The number of arbitrators and method of selection follow the parties' agreement. If unspecified, Henning sends each party an identical list of names (at least three for a single arbitrator, at least five for a three-member panel) and each side may strike one. Henning appoints from the names not stricken. Arbitrators must be independent and impartial with an ongoing disclosure obligation. Ex parte contact with appointed arbitrators is prohibited.
Rule 04Conduct of the Arbitration Proceedings
The Tribunal runs the matter expeditiously and confidentially and rules, finally, on challenges to jurisdiction and the scope of the arbitration agreement. An initial Case Management Conference sets the schedule for discovery, motion practice, hearing dates, and the form of the award. Pre-hearing submissions are due at least ten days before the hearing. Hearings may be in person, telephonic, or by video; subpoena, exclusion, and sequestration powers are available.
Rule 05Award
Awards are written and signed by the joining Tribunal members, by majority vote on panels of more than one. The parties select the award form at the Case Management Conference: Simple, Reasoned, or Findings of Fact and Conclusions of Law. The final award is rendered within thirty days after the close of the hearing. Motions to correct, modify, or reconsider are due within ten days. Awards are enforceable under the Federal Arbitration Act (9 U.S.C. § 1 et seq.).
Rule 06Henning Fees and Costs
Henning maintains the fee schedule for the Initial Case Deposit and advises parties of arbitrator billing rates, expense charges, and cancellation policies. After the Case Management Conference, Henning issues a Case Deposit invoice based on the estimated time and cost of the matter; additional invoices may follow. Unused deposits are refunded at case close. Failure to pay a deposit when due may stay the proceeding and the Tribunal may issue an award in the unpaid amount on its own motion.
Key Features
What Sets Henning Rules Apart
Active case management
Tribunal-led scheduling and prompt rulings keep matters moving.
Discovery scaled to the matter
Set at the Case Management Conference, not by a fixed civil-rules template.
Strike selection
Each side strikes from an identical list drawn from Henning's vetted panel.
Streamlined procedure
With a final award within thirty days of hearing close.
Transparent fees
Published Initial Case Deposit; no filing fees; unused balance refunded.
In-person or virtual
Hearings, or any portion, may be conducted remotely by agreement or order.
Confidential by default
Proceedings, submissions, and awards are private to the parties.
Enforceable awards
Final awards confirmable under the Federal Arbitration Act (9 U.S.C. § 1 et seq.).
Flexible Rules
If the parties' agreement designates a different rule set, including
another provider's published rules or custom rules negotiated by the
parties, Henning will administer the matter under those rules. Please
include a copy of the applicable rules when initiating.
Costs
Fees
$1,500
Initial Case Deposit
per party
At filing
Each party tenders $1,500: the Claimant with the Notice of Arbitration, and each Respondent within twenty days of Henning's Notice of Acceptance.
After filing
This deposit rolls into any future deposits required as the case proceeds. Any remaining balance is refunded at case close, less fees and expenses accrued.
Applied as-incurred
Drawn down against arbitration fees and expenses, not a fixed charge.
Credited or refunded
Unused funds carry forward against later invoices and are refunded at case close.
Allocation by award
Each party posts its own deposit; final allocation follows the parties' agreement or the Tribunal's award.
Arbitrator rates vary
Rates, expense charges, and cancelation policies are set by each neutral; see the bio for a specific neutral's rate.
Non-payment stays proceedings
If a deposit goes unpaid, Henning may stay the arbitration, and the Tribunal may issue an award for the unpaid amount.
Arbitration Formats
Which Type is Right for Your Case?
Binding Arbitration
Final. Enforceable. Certain.
The arbitrator's award is final and binding on all parties, enforceable in any court of competent jurisdiction. Grounds for appeal are extremely narrow: limited to fraud, corruption, or arbitrator misconduct. Binding arbitration provides the certainty of a resolution without the risk of a runaway verdict.
Upon agreement of counsel, Henning will consider administering mass arbitrations
submitted under arbitration rules stipulated by the parties. Acceptance is
discretionary and decided after an Administrative Arbitrator reviews the matter
and conducts a case management conference with counsel.
What qualifies
A group of 25+ related arbitrations
Henning treats as a "mass arbitration" any matter in which all three apply:
Claimants are jointly represented by one or more counsel
Claims include common claims against one or more related respondents
Respondents are jointly represented by one or more counsel
How it proceeds
From submission to case management
Submission
Counsel submit the matter for Henning's consideration.
Administrative Arbitrator appointed
Henning appoints an Administrative Arbitrator to review the proposed arbitration.
Case management conference
The Administrative Arbitrator conferences with counsel on claims, parties, location, and other administrative considerations.
Fees and procedures set
Additional fees and procedures are established at or after the conference.
An initiation deposit applies on submission and is refundable in part if Henning
declines the matter or a party withdraws after the case management conference.
Details are provided on intake.
Submit a mass arbitration for Henning's consideration. An Administrative Arbitrator
will review the matter and conduct a case management conference with counsel.
Coin-Operated Amusement Machines
Looking for COAM Arbitration?
COAM disputes referred by the Georgia Lottery Corporation follow a separate
process with strict deadlines, including a 14-day window to file a Demand
for Arbitration after referral. Henning administers COAM matters on a
dedicated track.
Pre-drafted clause language commonly used in commercial agreements. Always have
counsel review before adoption.
Arbitration Clause
Any controversy or claim arising out of or relating to this Agreement or the breach thereof, shall be settled by binding arbitration administered by Henning Mediation & Arbitration Service, Inc. (Henning) in accordance with its rules, and judgement upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. The arbitration hearing and all proceedings in connection therewith shall take place in Atlanta, Georgia. The arbitration shall be conducted by one or more arbitrators selected by the parties from Henning panel of arbitrators, or, if they are unable to agree on the selection, by one or more arbitrators appointed by Henning. The arbitration hearing shall be commenced within 90 days of the filing of a Demand for Arbitration by either party, and the award shall be rendered within 30 days of the conclusion of such hearing.
Arbitration clauses may specify the arbitration rules that the parties want to use. Henning has its own arbitration rules, but will use any other arbitration rules that the parties may specify. Parties may also include other details in their agreement to arbitrate, including the number of arbitrators, location of the arbitration, how soon the arbitration hearing must be commenced, and other matters.
Need Custom Language?
Use our interactive ADR clause generator to configure scope, rules, arbitrators,
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