Del. Rap. Arbit. R. 18
The parties generally are expected to cause non-privileged information in the possession, custody or control of their employees, agents and retained professionals to be produced, to the extent such information is subject to exchange under Rule 17. The parties are also expected to produce their employees, agents and retained professionals for deposition, to the extent the Arbitrator determines that the prehearing exchange of information should include depositions of such persons.
Unless otherwise provided in the Arbitration Agreement, the Arbitrator may compel the attendance of witnesses and the production of books, records, contracts, papers, accounts and all other documents and evidence. If, but only if, the Arbitration Agreement so provides, the Arbitrator may issue subpoenas or commissions to permit depositions to be taken, and in such case the Arbitrator may specify the manner in which and the terms on which such depositions shall be taken. In addition, the parties may seek information from third parties by means of subpoena or otherwise, and the Arbitrator may issue such orders in aid of such requests for information as the Arbitrator may deem appropriate for the timely, efficient and orderly resolution of the Arbitration.
Del. Rap. Arbit. R. 18