1. Parties and Contract. Differences exist regarding the performance of and obligations under a contract dated [date], between [name] and [name] (Parties). Differences also exist between Parties regarding mutual claims and demands arising from the sale of [property] by [name] to [name] in [year].
2. Submission of Claims to Arbitration. To fully settle all such claims disputed, Parties agree that all such claims and disputes be submitted to [name] and [name] (Arbitrators), as well as to a disinterested third party that two Arbitrators shall name, in accordance with Paragraph 3.
3. Selection of Third Arbitrator.
a. Qualifications. Third Arbitrator should be a person who has had experience in the business of [nature of business]. If a qualified person in this field cannot be found and agreed upon, two Arbitrators shall use their own discretion and select third Arbitrator who they deem appropriate.
b. Time of Selection. Third Arbitrator must be selected within [number] days after the signing of this Agreement. If not selected within that time, Parties may select third Arbitrator as promptly as possible, if either Party to this Agreement requests in writing tat this be done.
4. Power of Arbitrators. Three Arbitrators are given full power to hear and finally determine and dispose of all claims and disputes between Parties at [city, state].
5. Place of Arbitration. The hearing will take place at [address] or at such other reasonable place as is chosen by Arbitrators, upon [number] days' written notice to each Party.
6. Arbitration Hearing. At the hearing, Parties may be represented by counsel. Documentary evidence and oral testimony may be presented. Neither Party may produce more than [number] witnesses.
7. Arbitration Award. Arbitrators will make their award in writing no later than [number] days after the hearing. The award will state (a) the amount, if any, due from either Party to the other, and when it is to be paid (but not later than [number] days after the award is made) and (b) the rights and duties of Parties in the matters involved.
The award must be signed by at least two of three Arbitrators. The decision of two of three Arbitrators will be binding on Parties. The award shall be filed in the office of the clerk of [court] of [county, state], and will be final. No Party has a right to appeal the award to any court or otherwise.
8. Payment of Fees. Each Party will pay Party's own attorney fees. Arbitrators may fix (a) their own fees and (b) fees of witnesses who come before them. These fees will be paid by Parties as determined by Arbitrators as part of their award.
9. Fees and Expenses. All fees and expenses payable in connection with the arbitration proceeding shall be shared by both Parties during the course of the arbitration proceeding, but shall be reimbursed in favor of prevailing Party after the arbitration award is rendered.
[signatures of parties]