Surveying the Split: More Theories on Confirming Awards Where There Are or Appear to Be More Than One Claim or Issue

摘要

An interim award also may be confirmed by a district court if the award: (1) was on an issue that was bifurcated, formally or informally, from the rest of the proceedings, (2) if not bifurcated, nevertheless was on a separate and independent claim, or (3) was tantamount to a final award because it addressed the only claim raised in the proceedings.