Respectfully Mrs. Graulau is addressing the following questions over each of
two issues heard and decided by lower tribunals as a single whole case for two
separated filed motion to vacate and motion to correct.

Issue I-Questions Presented Over Motion to Correct

- Whether for respondent 's counterclaim arbitrator has awarded upon a matter not
submitted to him by petitioner or referred by the court not bind to arbitration
agreement?

- Whether there is not a valid arbitration agreement for respondent 's counterclaim
which is a matter only for the court to decide?

-Whether obligations under arbitration agreement ended upon termination of the
contract from which it was annexed/derived?

Issue II-Questions Presented Over Motion to Vacate

- Whether the courts below has interpreted important precedential case Hall St.
Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576, 584 (2008) and the Federal
Arbitration Act, in a way that is in direct conflict with other relevant controlling
precedent of this Court, Florida Supreme Court and Circuits opinions that is
contrary to provision under U.S. Federal Code?

-Whether "manifest disregard " of law is a basis for vacatur re'conceptualized
within the exclusive grounds under 9 U.S.C. § 10?

- Whether there is "complete diversity " jurisdiction on the face of motion to vacate?

-Whether petitioner 's claims are not time bared; time statutes limitations
nonjurisdictional subject to federal-state toll laws and equitable tolling doctrine?

- Whether for petitioner 's claims arbitrator engage in partiality, misconduct, and/or
exceeded his power?

- Whether petitioner 's claims are not longer suitable for arbitration?

Whether arbitrator exceeded his powers by awarding on a matter not submitted to him