International arb associates: in general, when does your team have the (almost) final draft ready for the client's review?

On a related question, how far in advance do you start preparing for the hearing (opening, cross, etc)?

I ask because our team is never able to produce a final draft until hours past the deadline (yes, we never meet the deadline set by the tribunal). And our partners don't tell us who should prepare for what until like a week or a few days before the hearing.

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I’m a mid- going on senior at one of the world’s largest international arbitration practices. The variability among teams and between matters is massive. Some teams are meticulous about sending a draft to the client two weeks early. This is common for sovereign representations. Other teams are pulling consecutive all-nighters to fix things or (re)draft which, frankly, should have been handled weeks prior. So it goes. Many people are on multiple overlapping filings or coming off other hearings and cannot devote enough attention to cases which require their review and sign-off.

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For hearings, I’ve been on matters where we began prepping about three months out and on matters where we’ll prep for a few weeks max. Depends on the size, complexity, the team’s experience, the strength of our briefs etc.

Having worked only a year in international arbitration in top rated teams: all filings have been sent past the deadline… the paralegal told me they never submitted anything on time and was super impressed when we finished only 2hours late. So I assume this is common practice

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Tbh, I have never missed a submission deadline and I would be incredibly ashamed if I did. Arbitral tribunal is put in a position to outright reject your submission if you are late and even AT and counterparty is cool enough to permit your submission I cant imagine late submission psychologically plays well with an AT. Optimally, the working draft for the document would be made ready for client's review a week ahead of deadline. It would be substantially finalized 3 days ahead and all format/exhibits would be ready for submission a day or two ahead of submission. I would never leave any work to the last day.

For hearings, it really depends on scope of hearings. If you have 15 witnesses and the hearing will take 5+ days - then I would start preparations a month in advance at least. Even longer if you have to do witness prep with high level executives.

Enjoy the letter writing campaign nit picking your learned colleagues’ late-submissions, but it’s a distraction from your case and a waste of your client’s money.

Every firm does things differently. In my current firm (civil law firm), there is a real demand to absolutely adhere to deadlines. This means respecting internal draft deadlines and external filing deadlines. Things get finalised in time. The firm is not afraid to push clients to give as much information as we need to complete our case in time.

In my previous firm (common law firm), we would stay up well past filing times and file whenever we could, however we could. That meant 7am finishes then next day, etc. This was usually preempted by internal deadlines being blown in the interest of prioritising other things on the case (eg: I can’t meet your internal deadline for turning this draft to you because I need X information from client still, etc).

As for hearings: I’ve never heard of firms not prioritising hearing prep (and certainly never leaving it to only a week before). That would surprise me. Hearing prep starts at minimum a month before and usually you’d see earlier due to deadlines from tribunals for things like hearing bundles, joint chronologies, etc.

In my team, we usually send the final draft to the client in instalments with the factual section always going first, usually about 2-3 weeks before its submission since that’s the section most dependent on client’s information and review. We aim to send the complete final draft 1 week before submission and let the client know that we will not be making any changes in the last 2-3 days before filing, unless it’s a make or break the case type of change.

We usually file well on time (like between 6 and 10pm) but that’s because the partner I work mostly with refuses to pull all-nighters. I filed twice late, around 4am both times, with a different partner but those were huge cases with much longer submissions.

I only did 2 full hearings (5 days each) and we started preparing both two months in advance. Cross-examinations and witness prep was done early and kept us busy every week, but preparing the opening and closing statements was much more of a last minute thing both times.

I can understand filing past the deadline from time to time because shit happens but if your team is always late and can never manage to file on time, then that means your partners (and senior associates) are ill-organised and doing a poor job of managing the case. It looks poor on the team and I can assure you that opposing counsel and the tribunal take note when one side is systemically late. Filings in arbitration can be such a logistical nightmare: being able to plan ahead and manage accordingly is an essential part of an arbitration practitioner’s skills.

A4, this sounds like a fantastic team.

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