Rejecting a party’s request for a court injunction to stop an arbitration proceeding on grounds that the proceeding was precluded by a previous arbitration award, the court held that the preclusive effect, if any, of a prior arbitration award must be determined by an arbitrator, not the court. Citigroup, Inc. v. Abu Dhabi Inv. Auth.,No. 13-06073 (S.D.N.Y. Nov. 25, 2013). The court found that preclusion is a merits-based defense to be decided by the arbitrator under the parties’ broad arbitration clause governing any dispute arising out of their transaction documents.