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(i) service of a detailed statement of claims, damages and <br />defenses, a statement of the issues asserted by each party <br />and positions with respect thereto, and any legal <br />authorities the parties may wish to bring to the attention <br />of the arbitrators, if appropriate; <br />(ii) stipulations to uncontested facts; <br />(iii) the extent to which discovery shall be conducted; <br />(iv) exchange and premarking of those documents that each <br />party believes may be offered at the hearing; <br />(v) the identification and availability of witnesses, including <br />experts, and such matters with respect to witnesses <br />including their biographies and expected testimony as <br />may be appropriate; <br />(vi) the extent to which hearings will proceed on consecutive <br />days; <br />(vii) the possibility of utilizing mediation or other non- <br />adjudicative methods of dispute resolution; and <br />(viii) the procedure for the issuance of subpoenas. <br />(b) By agreement of the parties and/or order of the arbitrators, the <br />pre - hearing activities and the hearing procedures that will govern <br />the non - binding arbitration will be memorialized in a Scheduling <br />and Procedure Order. <br />(c) During the course of the proceedings: <br />(i) The arbitrators shall take such steps as they may deem <br />necessary or desirable to avoid delay and to achieve a <br />just, speedy and cost - effective resolution of the matter. <br />(ii) All parties to the non - binding arbitration shall cooperate <br />in the exchange of documents, exhibits and information <br />within such party's control if the arbitrators consider such <br />production to be consistent with the goal of achieving a <br />just, speedy and cost - effective resolution of the matter. <br />(iii) The exchange of information pursuant to this rule, as <br />agreed by the parties to the non - binding arbitration and/or <br />directed by the arbitrators, shall be included within the <br />Scheduling and Procedure Order. <br />