New York Arbitration Week 2026
U.S.-Style Depositions in International Arbitration? Pros and Cons of Adding this Tool to Your Case
Freshfields International Arbitration Partner Caroline Richard will be speaking on a panel titled "U.S.-Style Depositions in International Arbitration? Pros and Cons of Adding this Tool to Your Case" on November 18, organized during New York Arbitration Week 2026.
International arbitration has traditionally relied on written witness statements, limited document production, and cross-examination at the hearing, with oral pre-hearing testimony generally treated as foreign to that model.
At the same time, as more cross-border disputes involve U.S. parties, U.S. counsel, and complex factual records, practitioners and tribunals are increasingly considering whether depositions could make fact-finding more efficient, narrow the issues before the hearing, and potentially facilitate earlier settlement.
On the other hand, there is concern that depositions could bring in the cost, delay, and adversarial tactics that parties often choose arbitration to avoid. The topic is particularly timely given the continued focus on balancing procedural efficiency with a thorough fact-finding process, and the broad discretion tribunals have to shape the procedure.
Moderator:
- Pedro José Izquierdo, Special Counsel, Sullivan & Cromwell
Speakers:
- Dustin Guzior, Partner, Sullivan & Cromwell
- Aníbal Sabater, Partner, Chaffetz Lindsey
- Caroline Richard, Partner, Freshfields
- Stephanie Cohen, independent arbitrator
For more information and registration, visit here.
