One way it could work is the court could allow the arbitrators to set the actual amount in conformity with their dec. The arbs coudl allow each side to work out the amount showing how they arrived at it and each would submit the amount to the panel who would then select one of the two or use some of the info from each presentation and come up withtheir own amount which would then be confirmed bu the court into an actual money judgment earning 9% per annum from its due date. (I beleive that is still the NY interest rate on judgments.