P1024 An arbitrator has authority to enforce a discovery subpoena against a nonparty to the arbitration; a nonparty's motion for protective order in such a case should be made before the arbitrator; a party's request for judicial review of the arbitrator's ruling on the motion is subject to the same limits as any other arbitration order, but if review is requested by the nonparty, the court has plenary (i.e., unqualified) authority to review it.CitationBERGLUND v ARTHROSCOPIC & LASER SURGERY CTR (Arbitration Discovery) 139 CA4 904 [See: CCP 2020.010, 1283.05; Alexander v Blue Cross 88 CA4 1082, P/AT 7/01; Moncharsh v Heily 3 C4 1]
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