You are a lawyer representing FINRA member Freedom Investments in a case brought by a former client, Bruce Lee.

• When Lee opened his account with Freedom, he signed an arbitration agreement in which he agreed to resolve all claims against Freedom Investments by filing a case in a court of competent jurisdiction.
• The agreement also included prohibitions against Lee's (a) filing a class action and (b) requesting punitive damages.
• The client has filed a FINRA arbitration claim against the Firm and the registered representative who handled the accounts at Freedom, Betty Ting, alleging damages of $150,000 based on claims of unsuitability, churning, breach of fiduciary duty and failure to supervise.

The case has progressed, and the parties are now seeking document discovery.

• Lee has failed to respond to Freedom's requests for documents and has not filed any objections.
• Freedom Investments has asked the arbitrators to sign a subpoena directed to the broker-dealer where Lee had his accounts prior to his opening an account at Freedom Investments.
• The subpoena is for records relating to Lee's account at that broker-dealer.
• Freedom Investments has also asked for a subpoena directed to Lee's accountant for records.
• The panel has signed the subpoena to the accountant, but the accountant is refusing to comply.

Based on the fact pattern set forth in parts 1 and 2, please answer the following questions.

1. The Claimant can seek information through interrogatories.
   • Please state whether you agree disagree and explain your answer.
2. Is Freedom Investments in compliance with FINRA rules by seeking records from another broker-dealer by subpoena? State your answer (yes or no) and then provide an explanation.
3. Does Freedom have any recourse against the Lee for not producing documents? Which FINRA rule applies and what are the possible outcomes?