On May 25, 2011, we reported on the denial of Northwestern National Insurance Co.’s petition to appoint a replacement arbitrator after opponent INSCO’s appointed arbitrator resigned in protest to perceived partiality by Northwestern’s appointee. The court has now disqualified INSCO’s counsel for improperly procuring from its former appointee, and then hiding, internal emails between members of the panel containing deliberations in the ongoing arbitration. INSCO’s counsel had requested the documents to substantiate its allegations that Northwestern’s appointed arbitrator was biased. The court found that it, rather than the panel, was the proper entity to determine attorney discipline and that INSCO’s counsel’s actions constituted “a serious violation of arbitral guidelines, as well as ethical rules.” Northwestern National Insurance Co. v. INSCO, Ltd., Case No. 1:11-cv-01124 (USDC S.D.N.Y. Oct. 3, 2011).