Help with a limited and simplified discovery

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I am still in the process of writing up all the papers that dh must file by Dec. 19, before his arbitration hearing on Jan. 5. He must file an IL Supreme Court Rule 222 Disclosure, which is a limited and simplified discovery. The Plaintiff (MBNA must file one as well).

Here is what he needs to state:

1. The factual basis of the claim or defense. In the event of multiple claims or defenses, the factual basis for each claim or defense.

2. The legal theory upon which each claim or defense is based including, where necessary for a reasonable understanding of the claim or defense, citations of pertinent legal or case authorities.

3. The names, addresses, and telephone numbers of any witnesses whom the disclosing party expects to call at trial with a designation of the subject matter about which each witness might be called to testify.

4. The names, addresses, and telephone numbers of all persons whom the party believes may have knowledge or information relevant to the events, transactions, or occurrences that gave rise to the action and the nature of the knowledge or information each such individual is believed to possess.

5. The names, addresses, and telephone numbers of all persons who have given statements, whether written or recorded, signed or unsigned, and the custodian of the copies of those statements.

6. Identity and address of each person whom the disclosing party expects to call as an expert witness at trial, plus the information call for by Rule 213(f).

7. The computation and the measure of damages alleged by the disclosing party and the document or testimony on which such computation and measure are based and the names, addresses, and telephone numbers of all damage witnesses.

8. The existence, location, custodian, and general description of any tangible evidence or documents that the disclosing party plans to use at trial and relevant insurance agreements.

9. A list of the documents or, in the case of voluminous documentary information, a list of the categories of documents, known by a party to exist whether or not in the party’s possession, custody or control and which that party believes may be relevant to the subject matter of the action, and those which appear reasonably calculated to lead to the discovery of admissible evidence, and the date(s) upon which those documents will be made, or have been made, available for inspection and copying. Unless good cause is stated for not doing so, a copy of each document listed shall be served with the disclosure. If production is not made, the name and address of the custodian of the document shall be indicated. A party who produces documents for inspection shall produce them as they are kept in the usual course of business.

It is TONS of information. Right now, I am working on #1 and #2, to begin with. I am looking for legal cases/titles to cite, specifically for #2. It's an arbitration case, again, and the CA is looking to confirm the award that was assigned by the NAF. Any suggestions as to where to look? TIA.

If you have any suggestions for the rest of the questions, feel free to comment!