Having covered the do’s and don’ts of drafting arbitration clauses in the first episode of this series, the second episode covers the first steps in an arbitration, including key strategic considerations in the early stages of an arbitration.  In particular, it will consider the following issues (and the related ICDR Rules): ·                  What considerations should parties bear in mind before deciding to commence an arbitration, including with respect to the time required to obtain a final award, and the costs involved?  How should the parties consider a settlement in the light of the time and costs of an ICDR arbitration?  ·                  If emergency relief is required, should parties commence proceedings before a court or before an arbitrator? ·                  How should parties and counsel approach the filing of initial arbitration documents (i.e. Notice of Arbitration and Answer and Counterclaim, Articles 2 and 3)?  ·                  After the filing of the initial arbitration documents, the ICDR Rules envision the possible holding of an initial Administrative Conference (Article 4) before the tribunal is constituted.  What can one expect at the Administrative Conference?