JAMS Arbitration Exhibit Requirements
JAMS Comprehensive Arbitration Rule 22(e) gives the arbitrator authority to set the exhibit exchange schedule, with a typical practice of requiring exchange 21 days before the hearing. Claimants label exhibits C-1, C-2, C-3 and Respondents label exhibits R-1, R-2, R-3. JAMS does not apply the Federal Rules of Evidence.
- JAMS Comprehensive Arbitration Rule 22(e) authorizes the arbitrator to set the exhibit exchange deadline; there is no fixed default in the JAMS rules.
- JAMS arbitrators typically require exhibit exchange 21 days before the hearing in complex commercial cases, though this varies by arbitrator and proceeding.
- Claimants in JAMS arbitration label exhibits C-1, C-2, C-3 (or C-001 for large productions); Respondents label exhibits R-1, R-2, R-3.
- JAMS Streamlined Arbitration Rules apply to disputes of $250,000 or less and involve more limited discovery and a single arbitrator rather than a panel.
- JAMS uses its proprietary online case management platform for document exchange and case submissions in most proceedings.
- The Federal Rules of Evidence do not apply in JAMS arbitration; the arbitrator has broad discretion to admit any relevant and material evidence.
- Privilege logs are still required in JAMS arbitration when documents are withheld on attorney-client privilege or work product grounds.
- JAMS International has separate exhibit procedures that may incorporate IBA Rules on the Taking of Evidence for cross-border disputes.
JAMS Exhibit Key Requirements
C/R Prefix Labels
Claimants use C-1, C-2, C-3. Respondents use R-1, R-2, R-3. Zero-padded numbering (C-001) recommended for large productions.
Rule 22(e) Exchange
No fixed default deadline—arbitrator sets the schedule. Typical practice: 21 days before hearing in complex commercial cases.
JAMS Online Platform
Documents exchanged via JAMS proprietary case management portal. Confirm access credentials and submission format with the case manager.
Evidence Discretion
Federal Rules of Evidence do not apply. Arbitrator has broad discretion to admit relevant and material evidence; privilege protections remain in force.
JAMS Streamlined vs. Comprehensive: Verify Which Rules Apply
Cases with $250,000 or less at stake may be subject to JAMS Streamlined Arbitration Rules, which involve more limited discovery and a single arbitrator. The exhibit exchange process differs under Streamlined Rules—depositions are not available as a matter of right, and the scope of document exchange is narrower. Confirm which rule set governs your arbitration before preparing your exhibits, as the pre-hearing schedule and exchange procedures differ significantly between the two.
JAMS Arbitration Exhibit Checklist
- Confirm which JAMS rule set applies (Comprehensive, Streamlined, Employment, or International)
- Request a scheduling conference early to establish the exhibit exchange deadline from the arbitrator
- Assign Claimant (C-1, C-2, C-3) or Respondent (R-1, R-2, R-3) labels to each exhibit
- Use zero-padded numbering (C-001) if your exhibit count exceeds 9 documents
- Obtain access credentials for the JAMS online case management platform from the case manager
- Prepare a formal exhibit list with label, description, date, and page count for each exhibit
- Exchange exhibit copies and exhibit list on all parties and the arbitrator by the scheduled deadline
- Prepare a privilege log for any documents withheld on attorney-client or work product grounds
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Frequently Asked Questions
What does JAMS Comprehensive Arbitration Rule 22(e) require for exhibit exchange?
JAMS Comprehensive Arbitration Rule 22(e) gives the arbitrator authority to set the schedule for document exchange, identification of witnesses, and submission of pre-hearing briefs. There is no fixed default deadline in the JAMS rules—the arbitrator determines the timeline based on the complexity of the case. In practice, JAMS arbitrators frequently require exhibit exchange 21 days before the hearing, but this varies by arbitrator and case. Parties should request a scheduling conference early in the proceeding to establish clear exhibit exchange deadlines.
How are exhibits labeled in JAMS arbitration?
In JAMS arbitration, Claimants label their exhibits C-1, C-2, C-3 and Respondents label their exhibits R-1, R-2, R-3. For large document productions, zero-padded numbering (C-001, C-002) is recommended so files sort correctly in the JAMS online case management platform and in electronic exhibit sets. Multi-party JAMS arbitrations may require a coordinated numbering scheme directed by the arbitrator at the preliminary conference.
What online platform does JAMS use for document exchange?
JAMS uses its proprietary online case management platform for document exchange and case management in most proceedings. Parties upload exhibits, briefs, and other submissions through the JAMS platform. The arbitrator's assistant coordinates access and document management. For smaller matters under JAMS Streamlined Rules, exchange by email or other agreed method may be acceptable. Confirm the required submission method with the case manager at the outset of the proceeding.
Are privilege logs required in JAMS arbitration?
Yes. Although JAMS does not apply the Federal Rules of Evidence, privilege protections—including attorney-client privilege and work product protection—are respected in JAMS arbitration. If a party withholds documents from exchange on the basis of privilege, a privilege log identifying the withheld documents, their general description, and the basis for withholding is still required. The arbitrator may rule on privilege disputes, including whether a log entry is sufficient.
When do JAMS Streamlined Rules apply instead of Comprehensive Rules?
JAMS Streamlined Arbitration Rules generally apply to disputes where the total amount in controversy is $250,000 or less (exclusive of interest and attorneys' fees), unless the parties agree otherwise. Streamlined cases involve more limited discovery, no depositions as a matter of right, and a single arbitrator rather than a panel. The exhibit exchange process under Streamlined Rules is still governed by the arbitrator's scheduling order, but the scope of document exchange is typically more limited than in Comprehensive proceedings.
How does JAMS arbitration compare to AAA for exhibit exchange purposes?
Both JAMS and AAA use the Claimant (C-1) and Respondent (R-1) prefix labeling convention. The primary procedural difference is that AAA Commercial Rule R-22 establishes a default 5-day exchange deadline, while JAMS Rule 22(e) gives the arbitrator complete discretion with no fixed default—JAMS arbitrators often set 21-day deadlines in complex commercial cases. JAMS tends to handle larger, more complex commercial disputes and may require more structured pre-hearing submissions. Each forum has its own online case management platform: JAMS uses its proprietary portal; AAA uses the Arbitration Management Platform (AMP).
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