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Uniform Commercial Arbitration Memorandum - Appendix XXII-B, page 1

Basic · 30/100Form Complexity Index

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What this form asks for

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The Uniform Commercial Arbitration Memorandum, designated as Appendix XXII-B, is a legal document used to prepare for commercial arbitration proceedings. It requires parties to provide a factual outline, list disputed and undisputed facts, detail legal issues, quantify damages, and describe defenses to streamline the arbitration process. Today, this form can be filled out quickly and accurately using AI-powered services like Instafill.ai, which can also convert non-fillable PDF versions into interactive fillable forms.

Fillable fields23

Pages2

Form Complexity IndexBasic, 30/100

The AI checks your answers before you download

14 checks built for this form, so a wrong date or a missing answer is caught before anyone else sees it.

Witness Count Format

Ensures the 'Number of Witnesses' field contains a valid, non-negative integer. This is important for scheduling and resource allocation for the arbitration hearing. If the validation fails, the user will be prompted to enter a whole number (e.g., 0, 1, 5).

Presentation Time Validity

Validates that the 'Anticipated length of time for your presentation' field contains a plausible time duration (e.g., '2 hours', '90 minutes'). This information is critical for the arbitrator to manage the hearing schedule effectively. An invalid or empty entry would prevent proper time allocation and could disrupt the proceedings.

Factual Outline Completeness

Checks that the 'Brief factual outline as to your position' (factsOutlineDesc) field is not empty. This section is the core of the memorandum, providing the arbitrator with a summary of the case. Failure to complete this field would render the form useless and result in a rejection of the submission.

Damages Quantification Requirement

Verifies that the 'Please quantify elements of your alleged damages' (issuesDamagesDesc) field is filled out. The arbitrator needs a clear, itemized breakdown of damages to make an informed decision. A submission without this information is incomplete and may be returned for clarification.

Party Service Status Selection

Ensures that a selection ('Yes' or 'No') is made for the 'Have all parties been served' (partiesServed) question. This is a critical procedural check to ensure due process has been followed. The form cannot be processed without this mandatory information.

Party Default Status Selection

Confirms that a selection ('Yes' or 'No') is made for the 'Are any parties in default?' (partiesDefault) question. This information is essential for the arbitrator to understand the status of all involved parties. An unanswered question will halt the submission process.

And 8 more checks

Conditional Unserved/Defaulted Party Listing
Conditional Arbitrator Expertise Specification
Signature and Printed Name Requirement
Certification Date Format and Logic
Attorney Representation Identification
Return Address Completeness
Legal Issues Completeness
Defense Basis Description Requirement

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How to Fill Out Appendix XXII-B Online for Free in 2026

What the AI walks you through.

Navigate to Instafill.ai and upload or select the Uniform Commercial Arbitration Memorandum (Appendix XXII-B).
Use the AI assistant to input your case information, including a brief factual outline, disputed facts, and undisputed facts.
Clearly define the legal issues for the arbitrator and provide a quantified breakdown of your alleged damages.
Detail any expert reports, discuss mitigation of damages, and describe the basis for your defenses in the appropriate sections.
Answer the procedural questions regarding service of parties, defaults, and any required special expertise for the arbitrator.
Carefully review all the information populated by the AI to ensure it is complete and accurately reflects your position.
Electronically sign and date the certification, then download the completed form to serve on all adversaries as required.

Common Mistakes in Completing Appendix XXII-B

The ones the AI is built to catch.

Failing to Quantify Damages

In section 5, filers often provide vague statements like 'significant damages' or 'to be determined' instead of a detailed, itemized breakdown. This happens due to a lack of preparation or uncertainty about the final figures. Failing to quantify damages undermines the claim's credibility and makes it difficult for the arbitrator to assess the case's value. To avoid this, clearly list each element of your alleged damages with a specific dollar amount for each.

Forgetting to Attach Expert Reports

A frequent procedural error is referencing expert reports in section 6 but failing to attach copies to the submission. This oversight can render the expert's findings inadmissible or cause significant delays as parties scramble to provide the missing documents. Always create a checklist and double-check that all referenced attachments are included with the final memorandum before submission.

Inconsistent Party Service Information

Users often create confusion by providing conflicting answers in sections 9, 10, and 11. For example, they might check 'No' for 'Have all parties been served?' but then leave section 11, which asks for a list of unserved parties, completely blank. This forces court staff to seek clarification and can delay the arbitration scheduling. Using a tool like Instafill.ai can help by using conditional logic to prompt for required information based on previous answers.

Vague or Narrative Factual Outline

In section 1, instead of a 'brief factual outline,' many filers submit a long, narrative-style argument that is difficult to follow. This happens when they try to argue their case instead of simply stating the core facts in a structured way. A verbose or disorganized outline can frustrate the arbitrator and obscure the key points of the position. It is crucial to present a concise, chronological, and neutral summary of the events in outline or bullet-point form.

Neglecting to Specify Arbitrator Expertise

Filers frequently leave section 12 blank, even when the case involves highly technical or industry-specific issues like construction defects or software disputes. This oversight risks having an arbitrator assigned who lacks the necessary subject-matter expertise, potentially leading to a misunderstanding of critical issues. Always consider if specialized knowledge would be beneficial and, if so, clearly specify the required discipline or industry.

Conclusory Statements for Legal Issues

In section 4, which asks for 'legal issues to be addressed,' filers often state their desired outcome (e.g., 'the defendant was negligent') rather than framing a precise legal question for the arbitrator to answer. This fails to properly guide the arbitrator's focus and shows a misunderstanding of the task. To avoid this, frame the issues as neutral questions, such as 'Did the defendant breach their duty of care under the terms of the contract?'

Incomplete or Illegible Signature Block

A surprising number of forms are submitted with a missing signature, an incorrect date, or an illegible handwritten name without a typed or printed version below it. This can invalidate the certification and cause the document to be rejected, requiring resubmission. Since this form is a non-fillable PDF, tools like Instafill.ai can convert it into a fillable version, allowing you to type your name and other details clearly before printing for signature, reducing the risk of illegibility.

Ignoring Mitigation of Damages

In section 7, many filers either ignore the 'mitigation of damages' section or incorrectly write 'N/A' without proper consideration. This is a strategic error, as it fails to proactively address a common defense and show the filer acted reasonably to minimize their losses. Failing to detail mitigation efforts can result in a reduced damages award, so you should always describe the steps taken to limit the financial impact of the incident.

Unrealistic Presentation Time Estimate

When asked for the anticipated length of their presentation, people often provide a guess that is either far too short or too long. An inaccurate estimate can lead to significant scheduling problems for the arbitration, potentially causing proceedings to be cut short or run excessively over time. To avoid this, carefully plan your presentation, including the number of witnesses and evidence review, to provide a realistic and well-considered time estimate.

Confusing Disputed Facts with Legal Arguments

In section 2, filers frequently list legal conclusions instead of the specific, discrete facts that are contested by the parties. For example, writing 'The contract was breached' is a legal argument, whereas 'The defendant failed to deliver the goods on the agreed-upon date' is a disputed fact. This mistake obscures the core factual disagreements the arbitrator must resolve. Stick to a clear, point-by-point list of contested factual statements in the requested outline form.

Frequently Asked Questions About Appendix XXII-B

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How does the AI fill out Appendix XXII-B?

You answer a few questions in plain words, or upload a document you already have. The AI reads what you give it and puts each answer into the right field of Appendix XXII-B, on every page, in seconds. It checks the answers against the form's own rules, and you review and change anything before you download, print or sign.

What happens to my information?

It is encrypted in transit and at rest, and it is never used to train AI.

How complex is Appendix XXII-B to fill out?

Appendix XXII-B has a Form Complexity Index of 30 out of 100, in the basic tier: 23 fillable fields across 2 pages. Instafill.ai's AI fills it in under a minute, with every field there for you to review before you download.

What is the purpose of the Uniform Commercial Arbitration Memorandum form?

This form is used to prepare for a commercial arbitration hearing by providing the arbitrator with a summary of your case. It outlines your factual position, disputed issues, legal arguments, and claimed damages to help streamline the process.

Who needs to fill out this form?

This form must be completed by the attorney representing a party in the arbitration. If a party is representing themselves (pro se), they are responsible for filling it out.

Where do I send the completed form?

The completed form should be sent to the address listed in the 'PLEASE RETURN TO' section at the top of page one. If this section is blank, you should contact the arbitration administrator or the court for the correct submission address.

What is the difference between 'disputed facts' and 'undisputed facts'?

Disputed facts are points of disagreement between the parties that the arbitrator must decide on. Undisputed facts are the details that all parties involved in the case agree are true.

What does it mean to 'quantify elements of your alleged damages'?

This requires you to provide a detailed breakdown of the monetary compensation you are seeking. You should list each component of your claim (e.g., repair costs, lost income) and the specific dollar amount for each.

Do I need to attach any other documents with this form?

Yes, Section 6 states that you must attach copies of any expert reports that you will be referencing or relying on in the arbitration.

Can the statements I make on this form be used against me in a court trial?

No, the note at the bottom of the form explicitly states that information provided on it cannot be used for evidentiary purposes in any trial of the matter.

What should I do if I believe the arbitrator needs special expertise?

In Section 12, you should specify any special expertise required, such as familiarity with a particular industry (e.g., construction, finance) or a specific technical discipline.

What information should I provide for 'mitigation of damages'?

In this section, you should describe the reasonable steps you took to minimize your financial losses after the incident that led to the dispute occurred.

What does it mean that I must certify the information and serve it on adversaries?

By signing the form, you are confirming the information is accurate and that you have sent a copy to the opposing party or their attorney, as required by Rule 4:21A-4.

Can AI help me complete this arbitration memorandum?

Yes, services like Instafill.ai can use AI to help you accurately auto-fill form fields with your information, saving time and helping to prevent errors.

How can I fill out this form online?

You can use a service like Instafill.ai to upload the PDF document. The platform allows you to fill out all the fields electronically, after which you can save, download, or print the completed form.

What can I do if my PDF copy of this form is not fillable?

If you have a non-fillable or 'flat' PDF, you can upload it to a platform like Instafill.ai. It can convert the document into an interactive, fillable form that you can easily complete on your computer.

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