CHAPTER - 3 - PRE-ARBITRATION & PRE-LITIGATION
Items covered in this chapter include :

Preparing for Litigation
Selection: Arbitration or Labour Court
The procedure for referring a dispute to arbitration
Time periods for referring disputes to the CCMA or Bargaining Council for Arbitration.
Notice of Arbitration
Jurisdiction of Arbitration
Postponement of Arbitration
Enforcement of collective agreements by Bargaining Councils
Witness subpoenas at the CCMA
Representation at the Arbitration
Procedure for referring the matter to the Labour Court
Contents of Schedule 2 form (Statement of claim)
The Respondent's Response to the Applicant's Statement of Claim
Calling of expert witnesses
The Pre-trial conference by parties
Pre-arbitrations meeting
Disclosure of documents
Pagination
Witness subpoenas in Labour Court
General Regulation 4 - Witness fees
Witness Subpoenas in the CCMA