What format should I file?

Most tribunals accept PDF for filings and exhibits. Use searchable PDF for documents with text, preserve original attachments, and keep a signed, tamper-evident copy for the record.

Can the appendix be e-signed?

Yes; electronic signatures are generally enforceable under the ESIGN Act (15 U.S.C. ch. 96) and UETA where adopted. Confirm tribunal rules and required signer authentication before e-signing.

Are notarizations required?

Notarization requirements depend on state law and tribunal rules. Some witness affidavits or verifications may need notarization or remote notarization depending on jurisdictional practice.

How should exhibits be numbered?

Use a single continuous exhibit numbering system (e.g., Ex. A-1, A-2) referenced in each chronology entry. Consistent numbering avoids confusion and speeds hearing preparation.

What if opposing counsel objects to a fact?

Note objections in the appendix log or cover letter and be prepared to produce supporting exhibits or witness testimony at the hearing to establish the fact.

How long should I retain appendix records?

Retain the appendix and exhibits for the full lifecycle of enforcement and any appeals; follow federal and industry retention rules such as IRS three-year minimums and HIPAA six-year requirements.

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Uniform Arbitration Statement of Facts Appendix

Uniform Arbitration Statement of Facts Appendix

This template is fully customizable. Edit the text, fill out the fields, and send it for signature. Give it a try!

APPENDIX XXII-A (R. 4:21A-4)

UNIFORM ARBITRATION STATEMENT OF FACTS

(Use for all but Commercial Cases)

Caption:

(Verbal Threshold) Yes No

Docket No:

Arbitration Date/Time:

Party Represented:

Auto:

P.I.:

I. Briefly describe the accident/incident occurred. (Please attach police report or expert liability reports):

II. Liability (Please attach expert reports)

III. Damages

A. Non-Economic Losses

1. List injuries (Please attach only hospital discharge summary and/or narrative reports/IME)

2. List objective testing and dates.

3. List current treatments and complaints.

B. Economic Losses (List all out of pocket expenses)

1. Itemized list of all medical bills

Treating Doctor/Hospital/Other Amount Total Amount Unpaid Bills

Revised 7/13/2000, CN 10505-English

page 1 of 1

What the Uniform Arbitration Statement of Facts Appendix Is

The Uniform Arbitration Statement of Facts Appendix is a structured attachment used in arbitration proceedings to present an orderly, factual summary of events, timeline entries, and supporting references. It organizes facts, identifies relevant documents and witnesses, and clarifies the factual basis for claims or defenses without argument. The appendix is intended to aid arbitrators in understanding disputed facts, expedite fact-finding, and provide a single-source record for evidentiary references. Parties often attach exhibits, document indices, and declarations to support entries in the appendix.

Why a Clear Statement of Facts Appendix Matters

A concise, well-organized appendix improves fact clarity, reduces disputes over foundational facts, and helps arbitrators move quickly to legal analysis within limited hearing time.

Who Typically Prepares and Relies on This Appendix

The appendix is usually prepared by counsel or a designated case manager for submission in consumer, commercial, or employment arbitration matters.

Arbitration Counsel and Case Teams: Organize evidence, link exhibits to fact entries, and coordinate witness statements for hearings.
In-House Legal and Compliance Teams: Use the appendix to document internal investigations and preserve an audit trail for regulatory or administrative review.
Claims Managers and Parties Pro Se: Provide a clear narrative and exhibit index when professional legal drafting resources are limited.

Core Components of a Professional Statement of Facts Appendix

A professional appendix follows a predictable structure so arbitrators and opposing parties can locate facts and supporting exhibits quickly.

Caption

Title, arbitration reference, parties' names, and filing date for clear identification.

Executive Summary

One-paragraph factual snapshot identifying the dispute, key dates, and what the appendix addresses.

Chronological Fact Entries

Dated entries with concise factual statements, exhibit citations, and witness references for each event.

Exhibit Index

Numerical or alphabetical exhibit list showing document title, date, and location of original evidence.

Witness List

Names, roles, expected testimony topics, and whether testimony is by declaration or live hearing.

Signature and Verification

Signature block for preparer and date; include verification statement if required by tribunal rules.

Step-by-Step: Completing the Appendix

Follow this ordered checklist when preparing the file to reduce revisions and ensure tribunal readiness.

01

Collect Documents: Gather all relevant records and label exhibits before drafting fact entries.
02

Draft Chronology: Write concise dated entries linking each fact to an exhibit.
03

Prepare Exhibit Index: Create a sequential index with descriptive titles for each exhibit.
04

Verify and Sign: Confirm accuracy, sign the verification, and prepare the filing package.

How to Configure an Online Appendix Workflow

Set up a consistent online template and routing to collect signatures, attestations, and exhibit attachments efficiently.

Field	Configuration
Document Template	Create a master appendix template with labeled fields and exhibit placeholders.
Signer Order	Set role-based signing order: preparer, opposing counsel acknowledgement, tribunal clerk if required.
Authentication	Use email plus SMS or KBA where tribunal rules require stronger signer identity.
Audit Trail	Enable full audit logging and attach completion certificates for the case file.

Typical Routing: From Preparation to Tribunal Submission

A consistent routing ensures everyone receives the same version and preserves chain of custody for exhibits.

Prepare Appendix: Draft facts, label exhibits, and attach supporting documents.
Internal Review: Have counsel or compliance review for accuracy and privilege issues.
Signatures & Verification: Collect electronic signatures and verification statements from preparers and witnesses.
File with Tribunal: Submit to the arbitrator or filing portal and distribute courtesy copies to opposing counsel.

Digital Signing and Submission Considerations

Record retention, exportable audit logs, and tamper-evident signed PDFs help satisfy tribunal evidentiary and recordkeeping expectations.

File Formats: PDF and DOCX are standard; ensure exhibits retain native formatting when required.
Authentication: Support email, SMS, and stronger KBA or SSO for high-assurance requirements.
Integrations: Platform should integrate with case management systems and cloud storage for easy filing.

Key Filing and Timing Dates to Track

Arbitral rules and scheduling orders set different deadlines; track filing, disclosure, and exhibit exchange dates carefully.

Exhibit Exchange Deadline:

Date for exchanging exhibits with opposing counsel per scheduling order.

Fact Appendix Filing:

Date by which the appendix must be filed with the tribunal.

Witness Statement Due:

Deadline for submitting witness declarations or affidavits.

Objection Window:

Period to lodge evidentiary objections to facts or exhibits.

Hearing Date:

Arbitration hearing start date where appendix will be relied upon.

Milestone Timeline for Appendix Preparation

Follow these stages sequentially to complete the appendix ahead of hearing and briefing deadlines.

01

Stage One: Evidence Collection

Compile documents, emails, and records to form the evidentiary base.

02

Stage Two: Chronology Draft

Create dated fact entries and cross-reference exhibits.

03

Stage Three: Review and Sign-off

Internal legal review and signature verification prior to distribution.

04

Stage Four: Tribunal Filing

Upload to the tribunal portal and serve opposing counsel.

Common Mistakes to Avoid

Misnumbered exhibits that prevent cross-referencing during hearings.
Argumentative language introduced into factual entries.
Missing verification or signature blocks required by tribunal rules.
Incomplete exhibit attachments or redaction errors that delay admissibility.

Risks and Consequences of an Incomplete or Incorrect Appendix

Evidentiary Exclusion: tribunal may exclude facts not properly supported by exhibits.

Delay: Opposing counsel objections can require re-filing and extend schedules.

Sanctions: Repeated failures may trigger tribunal sanctions or cost awards.

Credibility Harm: Inaccuracies can damage a party's credibility before the arbitrator.

Lost Issues: Key facts omitted may be unavailable later in proceedings.

Privilege Waiver: Improper exhibit disclosures can waive privilege unintentionally.

eSignature Vendor Comparison for Appendix Preparation and Signing

Compare common vendor pricing and core constraints that affect high-volume filing, HIPAA workflows, and envelope limits when planning appendix distribution.

	signNow	DocuSign	Adobe Sign	PandaDoc	HelloSign
Starting Price	$8/user/mo	$15/user/mo	$14/user/mo	$19/user/mo	$15/user/mo
Free Trial	7-day trial	Varies	Varies	Varies	Varies
Bulk Send	Yes	Yes	Yes	Yes	No
HIPAA Compliant	Yes	Yes	Yes	No	No
Envelope Cap	No cap	100/envs/user/yr	Varies	Varies	Varies

Practical Examples of Appendix Use in Arbitration

These brief case sketches show common ways parties structure fact appendices and supporting exhibits.

Employment Dispute Example

A former employee submits a chronology of communications and a witness list

Chronology cites emails as Exhibits 1–10
The appendix helped the arbitrator focus deposition questioning and shortened the hearing by a full day due to clear exhibit mapping and witness topic summaries.

Commercial Contract Example

A supplier and buyer attach delivery logs and acceptance certificates

Entries point to signed delivery receipts and invoices
The appendix clarified contract performance dates, enabled narrow evidentiary rulings, and limited surprise document production during the hearing.

Frequently Asked Questions and Troubleshooting

Answers to common questions about preparing, signing, and submitting a Uniform Arbitration Statement of Facts Appendix.

Need help? Contact support

What format should I file?
Most tribunals accept PDF for filings and exhibits. Use searchable PDF for documents with text, preserve original attachments, and keep a signed, tamper-evident copy for the record.
Can the appendix be e-signed?
Yes; electronic signatures are generally enforceable under the ESIGN Act (15 U.S.C. ch. 96) and UETA where adopted. Confirm tribunal rules and required signer authentication before e-signing.
Are notarizations required?
Notarization requirements depend on state law and tribunal rules. Some witness affidavits or verifications may need notarization or remote notarization depending on jurisdictional practice.
How should exhibits be numbered?
Use a single continuous exhibit numbering system (e.g., Ex. A-1, A-2) referenced in each chronology entry. Consistent numbering avoids confusion and speeds hearing preparation.
What if opposing counsel objects to a fact?
Note objections in the appendix log or cover letter and be prepared to produce supporting exhibits or witness testimony at the hearing to establish the fact.
How long should I retain appendix records?
Retain the appendix and exhibits for the full lifecycle of enforcement and any appeals; follow federal and industry retention rules such as IRS three-year minimums and HIPAA six-year requirements.

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