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Discussion of pre-hearing steps: (1) know the contract; (2) get the facts; (3) develop a theory. Discusses both grievance arbitration and arbitration of wages and other contract terms (a/k/a interest arbitration).

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Discussion of procedural questions in arbitration regarding pre-hearing statements or briefs, pre-hearing conferences, and discovery. Emphasizes the needs to avoid undue formalism and legalisms and to streamline the process. Suggests interrogatories, inspection of documents, and stipulations are more useful than depositions in arbitration. Briefly discusses jurisdictional disputes where only one of the involved unions is …

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