February 14, 2022

An arbitrator's award of attorneys' fees.

The arbitrator's authority extends only to those issues that are expressly presented by the parties, and, therefore, the award of fees must be demanded. A prayer for such other relief as is just and proper is not a demand for fees. 

Matter of 544 Bloomrest, LLC v. Harding, NY Slip Op 00936 (1st Dep't February 10, 2022)

Here is the decision.