Resolving Disputes with
Skill & Integrity

Understanding the Process

What Is Arbitration?

A private, binding resolution from an experienced neutral — faster and more efficient than traditional courtroom litigation or trials.

Arbitration is a private adjudicative process in which the parties present their case to a neutral decision-maker — the arbitrator — who hears evidence, considers arguments, and renders a binding decision called an "award." Think of it as a private trial: the arbitrator serves as the judge, but the process is faster, more flexible, and entirely confidential.

Unlike mediation, where the neutral facilitates negotiation, the arbitrator's role is to decide the case. The parties agree in advance to be bound by the arbitrator's decision, and the grounds for challenging an arbitration award in court are extremely limited — which means arbitration delivers the finality that a trial often cannot.

How Arbitration Works

The arbitration process at Conner ADR is structured to balance thoroughness with efficiency:

• Agreement to Arbitrate: Arbitration begins with the parties' agreement. This may be a clause in an existing contract (requiring future disputes to be arbitrated) or a submission agreement entered into after a dispute arises. The agreement establishes the scope of the arbitration and any rules that will govern the proceeding.
• Preliminary Conference: The arbitrator meets with the parties and/or counsel to establish ground rules, set a discovery schedule (if any), identify the issues to be decided, and set the hearing date. This conference ensures the proceeding stays focused and moves efficiently.
• Limited Discovery: Unlike litigation, where discovery can consume months or even years and enormous expense, arbitration typically involves limited, targeted discovery — document exchanges and, where necessary, depositions of key witnesses. The arbitrator has the authority to resolve any discovery disputes quickly and pragmatically.
• The Hearing: The arbitration hearing resembles a bench trial. Each side presents opening statements, calls witnesses, introduces documentary evidence, and makes closing arguments. The rules of evidence are relaxed — the arbitrator has broad discretion to admit relevant evidence — and the proceedings move more quickly than a courtroom trial.
• The Award: After the hearing, the arbitrator issues a written award, typically within 30 to 60 days. The award may be a simple decision or a reasoned opinion explaining the arbitrator's analysis. Once issued, the award is final and binding and can be confirmed and enforced by a court.

When Is Arbitration the Right Choice?

Arbitration is well-suited to disputes where:

• The parties need a binding decision but want to avoid the cost and delay of litigation.
• A contract between the parties contains an arbitration clause.
• Confidentiality is important — the parties don't want their dispute aired in a public courtroom.
• The subject matter is technical or specialized and benefits from a decision-maker with relevant experience (rather than a randomly assigned judge or jury).
• Finality matters — the parties want a decision that is not subject to years of appellate review.
• Scheduling flexibility is important — arbitration hearings can be set on the parties' timeline rather than the court's docket.

Advantages of Arbitration Over Litigation

Factor	Arbitration	Traditional Litigation
Speed	Typically resolved in months	Often takes years to reach trial
Cost	Streamlined discovery; condensed hearings	Extensive discovery, motion practice, and trial preparation
Privacy	Entirely confidential; no public record	Public filings, open courtroom
Decision-Maker	Experienced neutral chosen by the parties	Randomly assigned judge; lay jury
Flexibility	Parties set the rules, schedule, and format	Governed by court rules and calendar
Finality	Award is final; very limited grounds for appeal	Judgment may be appealed; further delay and expense
Enforceability	Award confirmed and enforced by court under state and federal law	Judgment enforceable, but subject to appellate modification

The Arbitrator's Role

A good arbitrator is more than a private judge. A good arbitrator manages the process efficiently, understands the subject matter of the dispute, treats the parties fairly, and issues a well-reasoned decision in a timely manner. Mike Conner brings decades of litigation experience to the arbitrator's chair — he has tried cases, examined witnesses, and argued motions on both sides of the kinds of disputes he now decides. That experience translates directly into a more informed, more efficient, and more fair-minded arbitration process.

Types of Disputes Suited for Arbitration

• Commercial contract disputes.
• Construction defect, delay, and payment claims.
• Real estate and property disputes.
• Business partnership and corporate governance disputes.
• Insurance coverage disputes.
• Employment and compensation disputes.
• Consumer and franchise disputes.
• Any dispute where a contract requires arbitration.

Legal Framework

Arbitration in Georgia is governed by the Georgia Arbitration Code (O.C.G.A. § 9-9-1 et seq.) and, for disputes involving interstate commerce, the Federal Arbitration Act (9 U.S.C. § 1 et seq.). Both statutes strongly favor the enforcement of arbitration agreements and provide a framework for confirming and enforcing arbitration awards through the courts. The grounds for vacating an arbitration award are narrow and well-defined, providing the parties with confidence that the process will produce a final, durable resolution.

Areas of Specialty

Disputes We Handle

Deep experience in the subject matter of your dispute — not just the process of resolving it.

An effective mediator or arbitrator needs more than process skills — they need to understand the substance of the dispute. Mike Conner's three decades of litigation practice across a broad range of civil matters means that when you bring your case to Conner ADR, your neutral already speaks your industry's language, understands the applicable standards, and knows what realistic outcomes look like at trial. That substantive expertise translates directly into more efficient proceedings and better results.

🩺 Serious Personal Injury & Wrongful Death

High-stakes personal injury and wrongful death cases present unique mediation challenges. The damages are often catastrophic and life-altering. The emotional stakes are extraordinarily high. The gap between the parties' positions can be enormous. And the insurance and coverage issues layered into these cases add further complexity. Mediating these disputes effectively requires a neutral who has actually tried serious personal injury cases and understands how juries evaluate damages, how defense counsel assesses exposure, and how plaintiffs' counsel values a case.

Mike Conner has prosecuted catastrophic personal injury cases throughout his career and is a member of both the Million Dollar Advocates Forum and the Multi-Million Dollar Advocates Forum. He has also defended injury claims on behalf of corporate and institutional clients and insurance carriers. That experience on both sides of serious tort litigation gives him the credibility and case valuation insight needed to help even the most adversarial parties find a path to resolution.

Types of personal injury and wrongful death disputes we handle:

• Catastrophic personal injury — traumatic brain injuries, spinal cord injuries, amputations, and severe burns
• Wrongful death claims — motor vehicle, premises liability, workplace, and product liability fatalities
• Motor vehicle and trucking accidents — including commercial carrier and multi-vehicle cases
• Premises liability — slip and fall, negligent security, and dangerous condition claims
• Product liability — manufacturing defects, design defects, and failure to warn claims
• Workplace injuries and employer liability claims
• Nursing home and assisted living negligence and abuse
• Insurance bad faith and coverage disputes arising from personal injury claims

🏢 Commercial Disputes

Commercial disputes strike at the heart of a business's operations, relationships, and bottom line. Whether it's a partnership gone wrong, a breached contract, a non-compete violation, or a dispute over the value of a business, the stakes are high and the issues are often both legally and financially complex.

Mike Conner has represented businesses of every size — from sole proprietors and family-owned companies to national corporations — in commercial litigation throughout his career. He has handled contract disputes, partnership dissolutions, corporate governance fights, franchise disputes, and business tort claims. That breadth of experience gives him the ability to quickly grasp the business dynamics driving a commercial dispute and help parties find practical, business-minded solutions.

Types of commercial disputes we handle:

• Breach of contract claims — supply agreements, service contracts, and distribution agreements
• Business partnership and LLC disputes — management disagreements, fiduciary duty claims, and dissolutions
• Corporate governance disputes — shareholder rights, officer/director liability, and derivative claims
• Non-compete, non-solicitation, and trade secret disputes
• Franchise disputes — territorial rights, termination, and encroachment claims
• Business valuation disagreements — buyouts, dissolutions, and fair value determinations
• Creditor and debtor disputes — guaranty enforcement, collections, and workout agreements
• Insurance coverage disputes — commercial general liability, professional liability, and D&O policies
• Banking and financial services disputes

🏗️ Construction Disputes

Construction disputes are among the most complex in civil practice. They involve layered contractual relationships, technical building standards, competing expert opinions, and frequently multiple parties — from owners and developers to general contractors, subcontractors, architects, engineers, and sureties. A neutral who doesn't understand construction is a neutral who will spend the first half of your mediation getting educated at the parties' expense.

Mike Conner has spent a significant portion of his career litigating construction cases. He has represented owners, general contractors, subcontractors, and design professionals in disputes ranging from residential defect claims to multi-million dollar commercial construction litigation. That experience means he understands the contracts (AIA, ConsensusDocs, and custom forms), the technical standards, the insurance coverage issues, and the way these cases actually play out at trial.

Types of construction disputes we handle:

• Construction defect claims — structural failures, water intrusion, code violations, and workmanship deficiencies
• Delay and disruption claims — schedule impacts, acceleration costs, and consequential damages
• Payment disputes — retainage, mechanic's liens, payment bond claims, and prompt pay act violations
• Contract interpretation and scope disputes — change orders, extras, and differing site conditions
• Design professional liability — architectural and engineering errors, design deficiencies, and code compliance failures
• Warranty claims and post-construction defects
• Surety bond disputes — performance bonds and payment bonds
• Insurance coverage for construction losses — CGL, builder's risk, and professional liability policies

🏠 Real Estate Disputes

Real estate disputes involve significant financial stakes, emotional investment, and often complex factual and legal issues related to title, disclosure, condition, and contractual obligations. Whether the dispute involves a failed residential closing, a commercial lease disagreement, or a multi-party development project gone sideways, an effective neutral needs to understand how real property transactions work and what can go wrong.

Mike Conner has extensive experience in real estate litigation and transactions, having represented developers, investors, brokers, property management companies, buyers, and sellers in a wide range of real property matters. He understands Georgia's real estate laws, the standard contract forms, the disclosure requirements, and the title issues that commonly give rise to disputes.

Types of real estate disputes we handle:

• Purchase and sale disputes — contract breaches, failed closings, and earnest money claims
• Seller nondisclosure and misrepresentation claims — latent defects, environmental issues, and material omissions
• Commercial and residential lease disputes — defaults, security deposits, maintenance obligations, and early termination
• Boundary, easement, and encroachment disputes
• Title disputes — ownership claims, liens, and quiet title actions
• Real estate development disputes — investor disagreements, joint venture conflicts, and entitlement issues
• Broker and agent disputes — commission claims, fiduciary duty violations, and professional negligence
• Homeowner and condominium association disputes
• Landlord-tenant disputes — commercial and residential eviction, lease interpretation, and property damage claims

⚕️ Professional Liability & Malpractice

Professional liability disputes involve claims that a licensed professional — a lawyer, doctor, accountant, engineer, architect, or other professional — failed to meet the applicable standard of care, causing damages to a client or patient. These cases carry unique dynamics: the professional's reputation and livelihood are at stake, insurance carriers and coverage issues are almost always involved, and the standard-of-care analysis often requires specialized knowledge that many neutrals simply don't have.

Mike Conner has represented professionals and institutions in malpractice defense and has prosecuted professional negligence claims on behalf of injured parties. He has also represented law firms, accounting firms, medical practices, and design professionals in a variety of business and liability matters. That experience gives him a practical understanding of professional standards, the insurance landscape, and the reputational concerns that drive settlement decisions in these cases.

Types of professional liability disputes we handle:

• Legal malpractice — missed deadlines, conflicts of interest, errors in advice, and settlement mismanagement
• Medical malpractice — misdiagnosis, surgical errors, medication errors, and failure to treat
• Accounting malpractice — audit failures, tax preparation errors, and negligent financial advice
• Design professional liability — architectural and engineering errors, plan deficiencies, and construction administration failures
• Insurance agent and broker errors and omissions
• Professional fee disputes
• Disciplinary and licensing matters arising from malpractice claims

⛪ Church Governance Disputes

Disputes within religious organizations are among the most sensitive matters a neutral can handle. They involve deeply held beliefs, long-standing personal relationships, and questions that touch on both spiritual authority and civil law. Church governance disputes can tear communities apart if not handled with care, discretion, and an understanding of the unique legal and organizational structures that govern religious institutions.

Mike Conner has served as legal counsel to multiple churches and religious institutions throughout South Georgia, advising on governance, employment, property, and organizational matters. That experience has given him a deep appreciation for the values, structures, and relational dynamics that define church life — and a practical understanding of how civil law intersects with ecclesiastical governance. He brings that sensitivity and knowledge to every church-related mediation.

Types of church governance disputes we handle:

• Pastoral and leadership disputes — selection, removal, authority, and succession conflicts
• Church property disputes — ownership, use, and disposition of real property, especially in denominational splits
• Congregational governance conflicts — voting rights, bylaws interpretation, and decision-making authority
• Church employment disputes — hiring, termination, compensation, and housing allowance disagreements
• Financial management disputes — stewardship, accountability, and allegations of mismanagement
• Denominational affiliation disputes — disaffiliation, realignment, and property trust clause conflicts
• Nonprofit governance issues — board conflicts, fiduciary duties, and organizational restructuring

👨‍👩‍👧‍👦 Divorce & Family Law Disputes

Divorce and family law disputes are among the most emotionally charged matters that come through any dispute resolution process. The issues are deeply personal — the future of a marriage, the custody and well-being of children, the division of a lifetime's worth of assets and debts. When these disputes land in court, the adversarial process often makes things worse, hardening positions, escalating conflict, and putting the family's most private matters into the public record.

Mediation offers a fundamentally different approach. It gives the parties — not a judge — the power to make the decisions that will shape their family's future. A skilled mediator helps divorcing spouses move past the anger and hurt to have productive conversations about what actually matters: what's best for the children, how to divide assets fairly, and how to structure the transition so both parties can move forward with dignity and financial stability.

Mike Conner's broad litigation background and experience with complex financial matters — including business valuations, real estate, retirement accounts, and tax issues — makes him particularly effective in mediating divorces that involve significant assets, business ownership interests, or contested financial questions.

Types of divorce and family law disputes we handle:

• Divorce mediation — contested and uncontested, including high-asset divorces
• Child custody and parenting plan disputes — legal custody, physical custody, and visitation schedules
• Child support disputes — initial determinations, modifications, and enforcement
• Alimony and spousal support — amount, duration, and modification disputes
• Property division — equitable division of marital assets including real estate, retirement accounts, and investments
• Business valuation disputes in divorce — closely held businesses, professional practices, and partnership interests
• Post-divorce modification disputes — changes in custody, support, or other terms
• Prenuptial and postnuptial agreement disputes
• Family business succession disputes arising from divorce

📜 Wills, Trusts & Estates Disputes

Few disputes carry as much emotional weight as conflicts over a loved one's estate. When a family member passes away, disagreements over the validity of a will, the administration of a trust, the conduct of a personal representative, or the distribution of assets can fracture families at the very moment they most need to support one another. These disputes also frequently involve complex legal questions — testamentary capacity, undue influence, fiduciary duty, trust interpretation, and tax consequences — that require a neutral with genuine legal sophistication.

Mike Conner has handled estate and trust matters throughout his career, including will contests, trust disputes, fiduciary litigation, and estate administration issues. His background in tax law — including a BBA in Accounting from UGA's Terry College of Business and admission to the United States Tax Court — provides an additional layer of expertise that is particularly valuable in estates disputes where tax planning, valuation, and generation-skipping issues are in play.

Types of wills, trusts, and estates disputes we handle:

• Will contests — challenges based on testamentary capacity, undue influence, fraud, or improper execution
• Trust disputes — interpretation, modification, termination, and challenges to trust validity
• Fiduciary disputes — claims against executors, personal representatives, trustees, and guardians for breach of fiduciary duty, self-dealing, or mismanagement
• Estate administration disputes — disagreements over asset valuation, distribution timing, creditor claims, and accounting
• Disputes among beneficiaries — unequal treatment, perceived unfairness, and conflicts over specific bequests
• Elder financial exploitation claims — allegations of financial abuse, undue influence over estate planning, and improper transfers
• Guardianship and conservatorship disputes — contested appointments, removal actions, and scope of authority
• Family business succession disputes — transition planning conflicts, buyout disagreements, and ownership disputes arising at death
• Charitable trust and nonprofit succession disputes

💼 Employment & Labor Law Disputes

Employment disputes are among the most common — and most consequential — conflicts in business. For employers, an unresolved employment claim can mean significant financial exposure, operational disruption, and reputational damage. For employees, these disputes involve their livelihood, their career trajectory, and often their sense of dignity and fair treatment. The stakes on both sides are real, and the emotional intensity of these cases can make them particularly challenging to resolve through traditional litigation.

Mike Conner has represented employers and employees throughout his career in a broad range of employment matters — from wrongful termination and discrimination claims to wage-and-hour disputes, FLSA class actions, and NLRB proceedings. He has counseled employers on hiring, discipline, termination, and compliance, and he has prosecuted claims on behalf of employees who have been treated unlawfully. That experience on both sides of the employment relationship gives him the perspective and credibility needed to mediate these disputes effectively.

Types of employment and labor law disputes we handle:

• Wrongful termination claims — including retaliatory discharge and constructive discharge allegations
• Employment discrimination — Title VII, ADA, ADEA, and state law claims based on race, sex, age, disability, religion, and national origin
• Sexual harassment and hostile work environment claims
• Wage and hour disputes — FLSA overtime claims, misclassification, unpaid wages, and collective actions
• Non-compete, non-solicitation, and confidentiality agreement disputes
• Severance and separation agreement negotiations
• Whistleblower and retaliation claims
• Family and Medical Leave Act (FMLA) disputes
• Workers' compensation retaliation claims
• Executive compensation and bonus disputes
• Employer-employee trade secret and intellectual property disputes
• Public sector and government employment disputes