See Festus & Helen Stacy Found, Inc. v. Merrill Lynch, Pierce, Fenner, & Smith Inc., 432 F. Supp. 2d 1375, 1379-80 (N.D. Ga. 2006). See Life Receivables Trust Syndicate 102 at Lloyd's of London, 549 F.3d 210, 218 (2d Cir. 2008) (arbitrators can order production of documents by a non-party witness only in connection with the witness' appearance at a hearing, including preliminary non-merits hearings) (citing Stolt-Nielsen SA v. Celanese AG, 430 F.3d 567, 577-79 (2d Cir. 2005)); Hay Group, Inc. v. E.B.S. Acquisition Corp., 360 F.3d 404, 406-07 (3d Cir. 2004) ("...Section 7's language unambiguously restricts an arbitrator's subpoena power to situations in which the non-party has been called to appear in the physical presence of the arbitrator and to hand over the documents at that time.").