Extract to table

Rules) Treaty Article 22 — titled "Arbitration" — mandates that "any dispute arising out of, or in connection with, this Treaty, including any question regarding its existence, validity, or termination, shall be referred to and finally resolved by arbitration" before a three-member arbitration panel sitting in New York, New York

The panel must specifically authorize the taking of depositions, and panels may limit the number and scope of depositions permitted

To compel third-party discovery, we must apply to a court of competent jurisdiction

CPLR § 3101(a) establishes the broad principle that "[t]here shall be full disclosure of all matter material and necessary in the prosecution or defense of an action, regardless of the burden of proof

Careful drafting is required to ensure that the most critical interrogatory topics are covered within this limit

Non-party subpoenas must be accompanied by the payment of witness fees