Except as necessary for FIG, the Companies, their subsidiaries, and their affiliates, and their respective successors or assigns or Novogratz to specifically enforce or enjoin a breach of this Agreement (to the extent such remedies are otherwise available), the Parties agree that any and all disputes that may arise in connection with, arising out of or relating to this Agreement shall be submitted to binding arbitration in New York, New York, according to the Employment Arbitration Rules of the American Arbitration Association. The Parties agree that each Party shall bear its or his own expenses incurred in connection with any such dispute. This arbitration obligation extends to any and all claims that may arise by and between the Parties or their subsidiaries or their affiliates and their respective successors or assigns. The Parties agree that any pending or contemplated arbitration hereunder may be consolidated with any prior arbitration arising under this agreement to arbitrate or an agreement to arbitrate set forth in the Separation Agreement for the purposes of efficiency and to avoid the possibility of inconsistent awards. An application for such consolidation may be made by any party to this Agreement or the Separation Agreement to the tribunal for the prior arbitration. The tribunal to the prior arbitration shall, after providing all interested parties the opportunity to comment on such application, order that any such pending or contemplated arbitration be consolidated into a prior arbitration if it determines that (i) the issues in the arbitrations involve common questions of law or fact; (ii) no party to either arbitration shall be prejudiced, whether by delay or otherwise, by the consolidation; (iii) any party to the pending or contemplated arbitration which did not join an application for consolidation, or does not consent to such an application, is sufficiently related to the parties in the prior arbitration that their interests were sufficiently represented in the appointment of the tribunal for the prior arbitral tribunal; and (iv) consolidation would be more efficient that separate arbitral proceedings.