If an arbitration is governed solely by the FAA, an arbitrator may not require non-parties to take part in any pre-hearing discovery outside the presence of the arbitrator. In the recent Eleventh Circuit Court of Appeals decision Managed Care Advisory Group, LLC v. Cigna Healthcare, Inc., — F.3d –, 2019 WL 4464301 (11th Cir. 2019), the Court considered summonses directed to non-parties to appear by video and to produce documents. The subpoenaed parties objected to summonses and took the position that they would not comply absent being ordered to do so. After an order from the United States District Court for the Southern District of Florida compelled the subpoenaed parties to comply with the summonses, the matter was appealed to the United States Court of Appeals for the Eleventh Circuit.