1. Write about both sides of the grievance - both the union and management
2. Explain in paragraph form what the arguments are of both sides
3. Include a total of 4 arbitration cases that have been decided on similar facts. This means that you will explain how these cases support the position you are explaining or how they go against the other side's position.
You can find cases at www.canlii.org or at various union sites.
4. Create a convincing argument for both sides using the cases and your interpretation of the facts. You are attempting to persuade the Arbitrator as if you are arguing for both sides. This section should have two conclusions; one for the Employer and one for the Union. You are stating your closing arguments.
5. Include references and footnotes, if applicable.