MEMORANDUM & ORDER Petitioners LTF Construction Company, LLC and LTF Club Operations Company, Inc. (collectively, “LTF”) filed the instant action against Respondent Cento Solutions, Inc. (“Cento”), seeking to confirm an arbitration award (“the Award”) totaling more than $1.8 million.1 Cento has moved to vacate the Award.2 For the reasons below, LTF’s petition is GRANTED, and Cento’s motion is DENIED. I. Background In February 2018, LTF and Cento entered into a contract (“the Contract”) related to the construction of a fitness club in Chappaqua, New York. (See Exhibit A to Centrella Decl. (“Contract”), dated Feb. 16, 2018 [dkt. no. 14-1] at 1.) LTF served as general contractor, and Cento was a subcontractor. (Id.) The relationship soon soured, however, and LTF filed a demand for arbitration with the American Arbitration Association (“AAA”) on September 20, 2018. (Exhibit B to Centrella Decl. (“Initial Statement of Claim”), dated Sept. 20, 2018 [dkt. no. 14-2].) LTF alleged numerous breaches of the Contract by Cento and sought damages of $815,000. (Id. at 1, 3-4.) The Contract provided that the AAA Construction Industry Arbitration Rules (“CIA Rules”) and the Federal Arbitration Act (“FAA”) would govern any arbitration. (Contract 11.3.) On April 23, 2019, Arbitrator Shamus P. O’Meara (“O’Meara”) held a preliminary hearing at which both parties’ counsel appeared. (Exhibit 8 to Ruzicka Aff., dated Apr. 23, 2019 [dkt. no. 19-8].) At the hearing, the parties (1) agreed to exchange their Statement of Claim and Statement of Counterclaim on June 17, 2019, (2) mutually requested a “standard award,”3 and (3) received notice that the hearing was scheduled to begin on November 11, 2019. (Id.
1, 10, 12.) The November 11 hearing was suspended due to ongoing mediation efforts. (See Exhibit 12 to Ruzicka Aff., dated Aug. 12, 2019 [dkt. no. 19-1].) Those efforts ultimately proved unsuccessful, however, and LTF pressed on with arbitration. (See Ruzicka Aff. 9.) Cento actively — if at times sporadically4 — participated in the arbitration proceedings. Specifically, Cento (1) responded to LTF’s claims and filed a counterclaim of its own, (see id. 22); (2) objected to the initial arbitrator’s selection before agreeing to proceed before O’Meara, (see Exhibit 2 to Ruzicka Aff., dated Mar. 4, 2019 [dkt. no. 19-2]); (3) appeared at a December 19, 2019 preliminary hearing where the parties agreed to exchange witness and exhibit lists by January 27, 2020, (see Exhibit 20A to Ruzicka Aff., dated Dec. 19, 2019 [dkt. no. 1922] 4), and (4) cooperated to set the arbitration hearing dates for March 2, 2020 to March 4, 2020, (see Exhibit 21 to Ruzicka Aff., dated Dec. 31, 2019 [dkt. no. 19-23]). But in mid-February 2020, Cento’s strategy changed. After Cento learned that it would cost about $35,000 to participate in the arbitration, James Centrella, Cento’s Managing Partner, determined that it would be more cost-effective not to appear at all. (See Centrella Decl.
