(a) By stipulation of the relevant Parties, any matter or issue pending before the Arbitrator may be submitted on an agreed statement of facts. The Arbitrator may permit arguments thereon, written or oral, and render an award based on the agreed statements submitted and such arguments.

(b) At any time prior to commencement of the hearing on the merits any Party may file a motion for summary judgment as provided for in the Code of Civil Procedure Section 437c. Where the declarations and affidavits filed therein by the Parties indicate that no triable issue as to any material fact exists, the Arbitrator shall enter the award based upon the facts, the law and the Contract.