Merger Agreement, Earnout, and Indemnity Escrow Disputes: Motion to Compel Arbitration and Stay — Full Package

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Merger Agreement, Earnout, and Indemnity Escrow Disputes

A motion to compel arbitration of a Merger Agreement, Earnout, and Indemnity Escrow Disputes dispute and to stay or dismiss the court case.

Includes a declaration establishing formation and assent, a memorandum on scope and delegation, and treatment of the unconscionability arguments the other side will raise. Getting to arbitration early usually saves more than the motion costs. Briefed from the record and the controlling authority in your circuit, with the procedural posture handled as carefully as the merits.

Frequently asked questions

The fee covers the motion and supporting memorandum, the declaration and exhibit set the motion relies on, and a proposed order in the court's preferred form. It is fixed at this scope: motion, memorandum, declaration, proposed order, and up to 5 exhibits. 2 rounds of revisions are included. If your matter falls outside that scope we tell you before starting and quote the difference — we do not bill past a flat fee without agreeing it first.

2 to 3 weeks from a complete set of instructions, plus time for the 2 rounds of revisions included in the fee. If you are working to a court deadline or a closing date, tell us when you order and we will confirm in writing whether we can meet it before you commit.

$7,800 is $325/hour × 24 hours — the time this deliverable takes in an ordinary merger agreement, earnout, and indemnity escrow disputes matter, at the firm's standard rate. Because it is a flat fee, the risk of the work running long sits with the firm: you pay $7,800 whether it takes us the estimate or twice it.

Third-party costs are never inside a flat fee and are passed through at cost, never marked up: court and agency filing fees, court reporter and transcript charges, expert witness fees, search vendor and e-discovery hosting charges, process server fees, and travel.

A short description of the dispute and where it currently stands, the key documents, contracts, and correspondence, the parties involved and any deadlines already running, and the case caption and court, if a matter has been filed. Send what you have — if something is missing we will tell you what else we need before the turnaround clock starts.

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