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The Potential Pitfalls of Contesting Arbitrability in the Arbitration

When an agreement to arbitrate contains a clear and unmistakable “delegation” provision, gateway questions of arbitrability are for the arbitrator to decide. See, e.g., Kubala v. Supreme Prod. Servs., 830 F.3d 199, 201-02...more

Pre-Arbitration Discovery: Turn to State Law Where the Federal Rules are Inadequate

As discussed in an earlier post, obtaining discovery from a non-party to an arbitration often is easier said than done. Depending on the law of the place of arbitration, arbitrators may not be able to compel document...more

Document Discovery From Non-Parties in Commercial Arbitration: Availability and Practical Considerations

Litigators in the U.S. often take for granted the ease with which they can obtain discovery from non-parties in our federal and state courts. One might assume that the “presumption in favor of arbitrability” embodied in the...more

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