Some issues between the parties may be resolved by way of a preliminary issue ('PI') hearing in advance of the main trial1. These might include: (1) disputes as to whether or not there was a binding contract between the parties; (2) disputes as to what documents make up or are incorporated within the contract between the parties and disputes as to the contents or relevance of any conversations relied on as having contractual status or effect; (3) disputes as to the proper construction of the contract documents or the effect of an exclusion or
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