On November 13, 2006, with respect to an NASD arbitration, a District Court entered an order remanding an arbitration award to the panel for a new damage award, finding that the award was in manifest disregard of law, and shocking to the conscience of the court. On April 9, 2007, the Court entered an Order denying a motion for reconsideration. Apparenly upset with the passage of time with no progress, the Order provides that if the panel does not enter a new damage award within 30 days, the court will issue an Order to Show Cause why the panel should not be held in contempt. Strobel v. Morgan Stanley Dean Witter, Case No. 04-1069 (S.D. Cal.).
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