WHEREFORE, Petitioners respectfully request that this Court:

a. Enter an Order pursuant to CPLR § 7510 confirming the Award.

b. Enter a judgment thereon in favor of Petitioners pursuant to CPLR § 7514, in the amount of $1,991,411.49, together with post-Award, pre-judgment interest at the statutory rate pursuant to CPLR § 5002 from July 1, 2020, through the date Judgment is entered; plus postjudgment interest at the statutory rate pursuant to CPLR § 5003 until payment is made; plus Petitioners' reasonable attorneys' fees and costs; and

c. Award Petitioners such other and further relief as the Court deems just and proper.

• Petitioners' Memorandum of Law is Support of Their Appliation for an Order Pursuant to Section 216.1(A) of the Uniform Rules Regarding the Sealing of Certain Documents  / July 13, 2020
  http://brokeandbroker.com/PDF/MiniconeMemoLaw200713.pdf
  
  

[T]he Tribunal found, nothing presented as evidence by Bridgewater throughout the Arbitration constituted a trade secret: 

[W]e find that the evidence presented establishes that the alleged trade secrets, that is, the trade secrets as described, constituted publicly available information or information generally known to professionals in the industry, and that Claimant [Bridgewater], a highly sophisticated entity, knew that the trade secrets as described did not constitute trade secrets. 

See Petition, Ex. 2 (Award at 17) (emphasis added). In addition to Bridgewater knowing that the information it alleged as "secrets" did not constitute trade secrets, the Tribunal found that Bridgewater manufactured false evidence regarding its alleged "secrets": 

We conclude that Claimant [Bridgewater] did not have a reasonable basis for filing its claims of misappropriation of trade secrets or disclosure of confidential information as to Squire or Minicone. We conclude Claimant filed its claims in reckless disregard of its own internal records, and in order to support its allegations of access to trade secrets, manufactured false evidence. 

Id. at 17 (emphasis added). Beyond the finding there were no trade secrets, the Tribunal also found that Bridgewater withheld evidence regarding its supposed "secrets" in defiance of the Tribunal's repeated orders: 

Finally, Claimant [Bridgewater] continued to press its claims even after discovery and the Tribunal's orders made it clear that Claimant's refusal to provide models and complete PEDs [Plain English Documents] foreclosed the possibility of prevailing on its misappropriation claims. Claimant's actions in continuing to press its claims constitute further evidence that its intentions were not to prove misappropriation, but rather, were to adversely affect Respondents' ability to conduct a competitive business. 

Id. at 17; see also id. at 19: 

Bridgewater defied the Tribunal's repeated orders to provide sufficient specificity for each of its alleged trade secrets to enable Respondents to determine what they were accused of misappropriating, thus making it impossible for experts and the Tribunal to compare Claimant's actual methodologies with TCM's methodologies. Claimant's refusal supports a negative inference,viz., that had the information been provided, it would have been obvious that Respondents' methodologies were not the same as Claimants.

• Memorandum of Law in Opposition to Petition to Confirm an Attorneys' Fees Award Where No Party Prevailed in an Arbitration, and Where the Controlling Agreements and Controlling Law Explicitly Prohibit Such Award / July 14, 2020
  http://brokeandbroker.com/PDF/BridgewaterMemoLaw200714.pdf