@fisthardcheese NY rules have a nifty burden-shifting provision that--if executed correctly--precludes plaintiff from objecting to arb if they receive a notice of intent to arb and don't apply to stay the arb within 20 days. This notice (per usctrojanalum) has to be sent to the plaintiff directly CMRRR, with a copy to the plaintiff's attorney.  New York Consolidated Laws, Civil Practice Law and Rules - CVP § 7503. Application to compel or stay arbitration;  stay of action;  notice of intent