Draft Dispositive Arbitration Motion

I have an employment-related arbitration already on the docket and I have to file a dispositive motion for summary judgment before the day is over. The entire argument hinges on a procedural defect that, if set out clearly, should dispose of the claimant’s case without the need for an evidentiary hearing.

Here is what I need delivered:

• A polished memorandum (Word format) that tracks the governing arbitration rules and any relevant state or federal authority.
• A concise statement of undisputed facts anchored by pinpoint citations to the record I will supply as PDFs.
• A proposed order that the arbitrator can sign.

Please structure the brief the same way you would for a federal summary-judgment motion—issue statement, legal standard, argument, and conclusion—but tailor citations and terminology to arbitration practice. Bluebook citation style is preferred, and I would like internal hyperlinks for easy navigation.

Timing is critical: I need the completed motion in my inbox no later than 6 p.m. (my local time) today so I can review and submit it.

If you have experience drafting dispositive motions in employment arbitration and can turn this around immediately, let’s get started.