Life Receivables Trust v. Syndicate 102 at Lloyd’s of London
2008 U.S. App. LEXIS 24977 (Nov. 25, 2008)
The Second Circuit held that section 7 of the Federal Arbitration Act (“FAA”) does not permit an arbitrator to compel pre-hearing document discovery from non-parties to the arbitration. However, the court noted that a non party could be subpoenaed to produce documents at a preliminary hearing on non-merits issues before one or more arbitrators.Continue Reading Second Circuit Holds Arbitrators Cannot, Under the Federal Arbitration Act, Compel Pre-Hearing Discovery of Documents of Third Parties, Except That Production May be Compelled at a Preliminary Hearing Before an Arbitrator