Judge: Armen Tamzarian, Case: 20STCV21355, Date: 2022-12-13 Tentative Ruling

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Case Number: 20STCV21355    Hearing Date: December 13, 2022    Dept: 52

Tentative Ruling:

Plaintiff Eyal Raziel’s Motion to Lift Stay on All Proceedings and Request for Sanctions

For a second time, plaintiff Eyal Raziel moves to lift the stay in this action.  Plaintiff argues defendants Farhad Eliasi, Elad Benisti, and Extended Vision, LLC dba Upper West Restaurant waived their right to compel arbitration under Code of Civil Procedure section 1281.97 because they did not timely pay arbitration fees.

Procedural History

On October 21, 2020, this court granted defendants’ petition to compel arbitration and stay the case pursuant to the parties’ arbitration agreement.  Plaintiff filed an arbitration demand with the American Arbitration Association’s (AAA) employment division.  Plaintiff then moved to lift the stay, arguing that defendants waived their right to compel arbitration.  AAA, relying on Code of Civil Procedure section 1284.3(a), would not proceed with the arbitration unless both sides agreed to waive the arbitration agreement’s provision that the prevailing party would recover attorney fees and arbitration fees.  Defendants did not agree to waive the provision, so AAA closed the matter.

On January 13, 2022, the court ruled defendants did not waive their right to enforce the arbitration agreement.  The court stated, “Although the subject matter of the dispute is employment, the agreement clearly calls for application of the Commercial Arbitration Rules.”  The order concluded, “Plaintiff fails to demonstrate waiver and therefore must proceed to arbitration pursuant to the parties’ contract—which provides for using the Commercial Arbitration Rules of the American Arbitration Association.  Once plaintiff does so, AAA—not this court—must decide whether the parties are required to waive any part of the contract.”

Arbitration with ADR, Inc.

After the court’s ruling on plaintiff’s last motion, the parties agreed to arbitrate with ADR Services, Inc. instead of AAA.  (Lowery Reply Decl., ¶ 9.)  They each “reserve[d] the right to have the arbitrator decide upon certain preliminary issues,” including “whether to apply the Commercial or Employment Rules, how to split the fees, and the availability of attorneys’ fees to the prevailing party.”  (Ibid.) 

ADR, however, informed the parties that it did not have that authority absent a written stipulation by the parties.  (Lowery Reply Decl., ¶ 10, Ex. M.)  ADR’s representative quoted the court’s January 13, 2022 minute order’s statement that “Once plaintiff [proceeds to arbitration], AAA—not this court—must decide whether the parties are required to waive any part of the contract.”  (Ibid.)  ADR’s representative wrote, “[A[lthough AAA may have the decision making authority to determine whether the parties are required to waive any part of the contract, please be advised that ADR Services, Inc. does not have the same decision making authority.”  (Ibid.)  In a second email, ADR’s representative wrote, “Please be advised that a Stipulation by the parties is necessary because the Minute Order dated January 13, 2022 states that AAA (not the arbitrator) must decide whether the parties are required to waive any part of the contract.”  (Lowery Reply Decl., ¶ X, Ex. N.)

The parties did not agree to any such written stipulation, and the proceeding with ADR did not go forward.

Plaintiff’s Second Arbitration Demand with AAA

            On August 26, 2022, plaintiff filed a new arbitration demand with AAA.  (Menges Decl., ¶ 4, Ex. 3.)  AAA sent defendants an invoice for $1,900.  (Id., 5, Ex. 4.)  On October 10, AAA closed the matter because defendants did not pay the fee.  (Id., ¶ 8, Ex. 7.)

Analysis

            Plaintiff’s motion fails for two reasons. 

            First, plaintiff never served the latest AAA arbitration demand on defendants.  “A demand for arbitration must be served on the other party.”  (Ikerd v. Warren T. Merrill & Sons (1992) 9 Cal.App.4th 1833, 1842.)  “A demand for arbitration is a pleading analogous to a complaint in a civil action.”  (Id. at p. 1844, fn. 10.)  “Personal jurisdiction” over a respondent requires “due process and service.”  (Id. at p. 1842.)  “[A]ctual knowledge of the proceeding alone is not enough.”  (Ibid.)

Defense counsel states, “[N]either my clients nor my office has ever been served with the AAA arbitration demand [plaintiff’s counsel] allegedly filed on August 26, 2022.”  (Catanzarite Decl., ¶ 9.)  When AAA sent defendants an invoice, counsel “had no knowledge plaintiff had filed any new arbitration claim with AAA.”  (Ibid.)  When defendants filed the opposition to this motion, they still had “not ever … been served with the alleged AAA demand for arbitration”  (Id., ¶ 12.) 

Plaintiff did not include a copy of the arbitration demand with his moving papers.  He attached a copy as Exhibit A to the declaration of Nathan T. Lowery in support of the reply.  No proof of service of the demand is attached. 

Without service of the demand, AAA’s invoice to defendants could not trigger the 30-day deadline under CCP § 1281.97(a).  AAA had no personal jurisdiction over defendants and therefore could not require them to pay fees.  

Plaintiff’s reply does not acknowledge defendants’ argument about service or attempt to dispute the facts.

Second, there is already an arbitration proceeding with ADR Services, Inc.  Defendants have not waived their right to continue with that proceeding.  ADR’s requirement that the parties stipulate to giving it additional decision-making authority was based on an overly strict reading of the January 13, 2022 minute order, which resulted in a misunderstanding.  That order referred to “AAA” instead of an arbitrator in general because plaintiff had already filed an arbitration demand with AAA.  At the time, AAA was the arbitrator.  The point of the order was that, instead of the court, the arbitrator—AAA, ADR, or whoever it may be—must decide the issue.  Moreover, the arbitrator’s authority to decide that issue did not come from this court’s order.  It came from the parties’ arbitration agreement.

Disposition

            The motion is denied.  Plaintiff Eyal Raziel must proceed with the arbitration with ADR Services, Inc.