| 8. Third parties. It is clear from the case law that |
arbitrators have the power under the UAA (Section 7) and the |
FAA (Section 7) to issue orders, such as subpoenas, to non- |
parties whose information may be necessary for a full and fair |
hearing. Amgen, Inc. v. Kidney Ctr. of Delaware County, Ltd., |
879 F. Supp. 878 (N.D. Ill. 1995) (holding that arbitrator had |
the power under FAA to subpoena a third party to produce |
documents and to testify at a deposition); Meadows Indem. Co. |
v. Nutmeg Ins. Co., 157 F.R.D. 42 (M.D. Tenn. 1994) (holding |
that because the burden was minimal, the nonparty would have |
to produce documents pursuant to arbitrator's subpoena under |
FAA); Stanton v. Paine Webber Jackson & Curtis, Inc., 685 F. |
Supp. 1241 (S.D. Fla. 1988) (upholding subpoena issued by |
arbitrator under FAA that nonparties must appear at prehearing |
conference and arbitration hearing); Drivers Local Union No. |
639 v. Seagram Sales Corp., 531 F. Supp. 364, 366 (D.D.C. |
1981) ("the Uniform Arbitration Act provides for the issuance |
of subpoenas by an arbitrator to non-party witnesses at an |
arbitration proceeding, to compel their testimony or the |
production of documents"); United Elec. Workers Local 893 v. |
Schmitz, 576 N.W.2d 357 (Iowa 1998) (holding that that Iowa |
Arbitration Act confers on arbitrators the power to subpoena |
nonparty witnesses); but see |
COMSAT Corp. v. National Science Foundations, supra; Integrity |
Ins. Co. v. American Centennial Ins. Co., supra. Some state |
arbitration laws broadly allow |