Judge: Bruce G. Iwasaki, Case: 24STCV08121, Date: 2024-07-31 Tentative Ruling

Case Number: 24STCV08121    Hearing Date: July 31, 2024    Dept: 58

Judge Bruce Iwasaki

Department 58


Hearing Date:             July 31, 2024

Case Name:                 Larry Schwartz v. OTTera, Inc.

Case No.:                    24STCV08121

Motion:                       Motion to Compel Arbitration

Moving Party:             Defendant TriNet Group, Inc. (“TriNet”)

Joined by:                   Defendants OTTera, Inc., Stephen L. Hodge, Steve Rifkin and Craig McEldowney (“Joinder Defendants”)

Responding Party:      Plaintiff Larry Schwartz

 

Tentative Ruling:     

 

            Defendant TriNet Group, Inc.’s Motion to Compel Arbitration is granted.  The action is stayed pending completion of arbitration pursuant to Code of Civil Procedure, section 1281.4. 

 

            Joinder Defendants’ request for joinder is granted.  Plaintiff’s claims against Joinder Defendants are also ordered to arbitration. 

 

 

 

I.  Background

 

            Plaintiff served as the Chief Revenue Officer of OTTera, Inc. pursuant to a four year written employment agreement.  Plaintiff alleges he suffered age discrimination while he was employed at OTTera, Inc.  Despite positive comments on his performance and a merit bonus in June 2023, Plaintiff was terminated on November 17, 2023.  Plaintiff alleges he was terminated without cause and he was entitled to receive those benefits applicable to termination without cause.  Approximately one month after his termination, Defendants moved to classify his termination as with-cause, which substantially changed the benefits to which Plaintiff was entitled to upon termination. 

 

            On March 29, 2024, Plaintiff filed a complaint against Defendants OTTera, Inc., TriNet Group, Inc., Stephen L. Hodge, Steve Rifkin and Craig McEldowney alleging (1) breach of contract and breach of the covenant of good faith and fair dealing; (2) harassment in violation of Government Code section 12940(j); (3) age discrimination in violation of Government Code section 12940(a); (4) failure to take steps necessary to prevent harassment and discrimination in violation of Government code section 12940(k); (5) wrongful termination in violation of public policy; (6) intentional misrepresentation; (7) failure to pay all wages due upon separation. (Lab. Code, §§ 201, 203).

 

II.  Discussion

 

            A.  Legal Standard

 

                        i.  Federal Arbitration Act (“FAA”)

 

            “The FAA applies to contracts that involve interstate commerce (9 U.S.C. §§ 1, 2), but since arbitration is a matter of contract, the FAA also applies if it is so stated in the agreement.”  (Davis v. Shiekh Shoes, LLC (2022) 84 Cal.App.5th 956, 963.)  In addition, the express incorporation of the FAA for the enforcement of this arbitration agreement incorporates the procedural provisions of the FAA. Under Victrola 89, LLC v. Jaman Properties 8 LLC (2020) 46 Cal.App.5th 337, the language regarding enforcement of the arbitration agreement under the FAA incorporates the FAA’s procedural requirements and renders CCP §1281.2(c) inapplicable.  (Victrola 89, LLC, supra, 46 Cal.App.5th at 344-345 (arbitration provision providing that “enforcement [of the arbitration agreement] shall be governed by the [FAA]” incorporated procedural provisions of the FAA and trial court erred when it denied the motion to compel per Code of Civ. Proc., section 1281.2, subd. (c).)

 

            Under California and federal law, public policy favors arbitration as an efficient and less expensive means of resolving private disputes. (Moncharsh v. Heily & Blasé (1992) 3 Cal.4th 1, 8-9; AT&T Mobility LLC v. Concepcion (2011) 563 U.S. 333, 339.) Accordingly, whether an agreement is governed by the California Arbitration Act or the Federal Arbitration Act, courts resolve doubt about an arbitration agreement’s scope in favor of arbitration. (Moncharsh, supra, 3 Cal.4th at p. 9; Comedy Club, Inc. v. Improv West Associates (9th Cir. 2009) 553 F.3d 1277, 1284; see also Engalla v. Permanente Med. Grp., Inc. (1997) 15 Cal.4th 951, 971-72 (“California law incorporates many of the basic policy objectives contained in the Federal Arbitration Act, including a presumption in favor of arbitrability [citation] and a requirement that an arbitration agreement must be enforced on the basis of state law standards that apply to contracts in general.”).)  “[U]nder both the FAA and California law, ‘arbitration agreements are valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.’” (Higgins v. Superior Court (2006) 140 Cal.App.4th 1238, 1247.)

 

                        ii.  California Arbitration Act (“CAA”)

 

             “On petition of a party to an arbitration agreement alleging the existence of a written agreement to arbitrate a controversy and that a party to the agreement refuses to arbitrate that controversy, the court shall order the petitioner and the respondent to arbitrate the controversy if it determines that an agreement to arbitrate the controversy exists, unless it determines that:

 

(a) The right to compel arbitration has been waived by the petitioner; or

(b) Grounds exist for rescission of the agreement.

(c) A party to the arbitration agreement is also a party to a pending court action or special proceeding with a third party, arising out of the same transaction or series of related transactions and there is a possibility of conflicting rulings on a common issue of law or fact.”  (Code of Civ. Proc.,  section 1281.2.)

 

            “The trial court may resolve motions to compel arbitration in summary proceedings, in which the trial court sits as a trier of fact, weighing all the affidavits, declarations, and other documentary evidence, as well as oral testimony received at the court's discretion, to reach a final determination.  The party seeking arbitration bears the burden of proving the existence of a valid arbitration agreement by a preponderance of the evidence, and the party opposing arbitration bears the burden of proving any defense, such as unconscionability by a preponderance of the evidence.”  (Mendoza v. Trans Valley Transport (2022) 75 Cal.App.5th 748, 718 (trial court properly decided plaintiff’s challenge to arbitration agreement despite delegation clause where plaintiff attacked contract formation and very existence of agreement to arbitrate).)

 

            “If a court of competent jurisdiction, whether in this State or not, has ordered arbitration of a controversy which is an issue involved in an action or proceeding pending before a court of this State, the court in which such action or proceeding is pending shall, upon motion of a party to such action or proceeding, stay the action or proceeding until an arbitration is had in accordance with the order to arbitrate or until such earlier time as the court specifies.”  (Code of Civ. Proc, section 1281.4, para. 1).)

 

            B. Evidentiary Objections

 

            Plaintiff’s objections to evidence submitted by Defendants are overruled.

 

            Defendant TriNet’s objections to the Schwartz Declaration are overruled.  No declaration by Joshua Boxer was filed.  The objection to any reliance on such a declaration is sustained. 

 

            C.  Defendant TriNet establishes an applicable arbitration agreement

 

                  i.  Defendant TriNet establishes an arbitration agreement subject to the FAA between itself and Schwartz that applies to the claims alleged against it

 

            Defendant TriNet HR III, Inc. began providing human resources services to OTTera, Inc. on October 1, 2023.  (M. Ycasas Dec., ¶6.)  Defendant TriNet Group, Inc., the parent company of TriNet HR III, moves to compel arbitration of Plaintiff Schwartz’s claims pursuant to the “Dispute Resolution Protocol” (“DRP”) contained in the Terms and Conditions Agreement (“TCA”) executed by Plaintiff as part of his employment with OTTera, Inc.  (C. Thompson Dec., ¶2.)  The DRP provides in bold type as follows:

 

“Subject to and without superseding the specific terms in subsections (a) through (f) below, the DRP expressly requires that arbitration will be used instead of going before a court (for a judge or a jury trial) and that NO JURY TRIAL WILL BE PERMITTED (unless applicable law does not allow enforcement of a pre-dispute jury trial waiver in the particular circumstances presented) for any dispute arising out of or relating to your co-employment with TriNet and/or arising out of or relating to your employment with your company, and for any dispute with an employee, officer, or director of TriNet or a TriNet customer.” 

(C. Thompson Dec., ¶10, Ex. A, Section 8, p. 5 of 8 (bold type removed).) 

 

            The TCA, including the DRP, is between “TriNet” and the acknowledging employee.  (C. Thompson Dec., ¶10, Ex. A, Sections 1 and 9, p. 1 of 8.)  “TriNet” is defined to include Defendant TriNet Group, Inc., “all of its direct and indirect subsidiaries (including, but not limited to your TriNet co-employer, as defined below), whether doing business in their own name or otherwise.”  (Id. at Section 1, p. 1.)  The “co-employer” is the company that the acknowledging employee works for and “is a TriNet Customer” and whose name appears on the employee’s wage statements.  (Id. at Section 1, p. 2.) 

 

            The DRP “covers any dispute arising out of or relating to our co-employment with TriNet, including your TriNet co-employer, and/or arising out of or relating to your employment with your company, as well as any dispute with an employee, officer, or director TriNet or of a TriNet customer (all of whom, in addition to TriNet customers, are intended to be beneficiaries of this DRP, including but not limited to, all claims whether arising in tort or contract and whether arising under statute or common law including, but not limited to, any claim of breach of contract, discrimination or harassment of any kind.”  (C. Thompson Dec., Ex. A, Section 8(a), p. 5.) 

 

            The DRP also expressly states that the FAA applies to the agreement:  “The Federal Arbitration Act (“FAA”) applies to this DRP.”  (C. Thompson Dec., Ex. A, Section 8(a), p. 5 of 8.)  “The FAA applies to contracts that involve interstate commerce (9 U.S.C. §§ 1, 2), but since arbitration is a matter of contract, the FAA also applies if it is so stated in the agreement.”  (Davis v. Shiekh Shoes, LLC (2022) 84 Cal.App.5th 956, 963.)  The FAA therefore applies to the DRP. 

           

            TriNet establishes that the DRP applies to Plaintiff’s claims against it, which include statutory and tort claims for discrimination, harassment and failure to prevent discrimination and harassment in violation of the Fair Employment and Housing Act, wrongful termination in violation of public policy and violations of the Labor Code.  (Complaint, Second through Seventh Causes of action.)  The Complaint alleges causes of action arising out of and relating to Plaintiff’s co-employment with Defendant TriNet Group, Inc. and OTTera, Inc.  (Complaint, ¶¶16-37.) 

 

              ii.  Defendant establishes that Plaintiff acknowledged and accepted the terms of the TCA

 

            “A record or signature may not be denied legal effect or enforceability solely because it is in electronic form.”  (Civ, Code, section 1633.7, subdiv. (a).)  “A contract may not be denied legal effect or enforceability solely because an electronic record was used in its formation.”  (Civ. Code, section 1633.7, subdiv. (b).)  “If a law requires a record to be in writing, an electronic record satisfies the law.”  (Civ. Code, section 1633.7, subdiv. (c).) 

 

            “An electronic record or electronic signature is attributable to a person if it was the act of the person. The act of the person may be shown in any manner, including a showing of the efficacy of any security procedure applied to determine the person to which the electronic record or electronic signature was attributable.”  (Civ. Code, section 1633.9, subdiv. (a).)  “The effect of an electronic record or electronic signature attributed to a person under subdivision (a) is determined from the context and surrounding circumstances at the time of its creation, execution, or adoption, including the parties' agreement, if any, and otherwise as provided by law.”  (Civ. Code, section 1633.9, subdiv. (a).) 

 

            TriNet establishes that Plaintiff acknowledged and accepted the terms of the TCA electronically.  TriNet maintains a password-protected online platform that provides clients and worksite employees (“WSEs”) access to certain employment policies, employee records and forms.  (C. Thompson Dec., ¶4.)  TriNet’s platform can only be accessed by a unique Login ID and password that each employee creates when he or she first accesses the platform.  (C. Thompson Dec., ¶¶7-9.)  Based on a review of TriNet’s date regarding the TriNet platform, Schwartz acknowledged and accepted the terms of the TCA through his individual TriNet platform on September 18, 2023.  (Id. at ¶10; M. Ycasas Dec., ¶7.) 

 

            Schwartz’s acknowledgment and acceptance of the TCA’s terms is also evidenced by the confirmation email sent to Schwartz’s email account on September 18, 2023.  (M. Ycasas Dec., ¶8, Ex. A.)  The email attaches a copy of the TCA and confirms that Schwartz accepted the terms of the TCA.  (Id.)  However, the copy of the email attached as evidence to the Ycasas declaration does not include a copy of the attachment.  (Id.)  On reply, TriNet submits additional evidence establishing that the TCA attached to Thompson’s declaration is the TCA that was in effect on September 18, 2023 and acknowledged and accepted by Schwartz on that date.  (E. Weiss, ¶¶4-6.)

 

            In response, Schwartz testifies that (1) he does not recall ever seeing the TCA before; (2) that when he visited the website on July 17, 2024, the TCA was not among the list of policies acknowledged and accepted by him; and (3) he found the TCA under the “Benefits Guide” with a note indicating that he had previously acknowledged the TCA or a version thereof.  (L. Schwartz Dec., ¶¶16, 18.) 

 

            Schwartz’s inability to recall the TCA does not rebut TriNet’s evidence that Schwartz accessed his individual employee portal with his unique Login ID and password and acknowledged and accepted the TCA on September 18, 2023.  Schwartz’s screenshot of his employee portal lists the TriNet Terms and Conditions with a note stating, “Please note that you have already acknowledged these Terms and Conditions (or a version thereof) on 9/18/2023.”  (Schwartz, Dec., Ex. D.)  Schwartz therefore submits no evidence refuting TriNet’s showing that he acknowledged and accepted the TriNet’s TCA on September 18, 2023.

 

            Based on the evidence presented, Schwartz acknowledged and accepted the TriNet TCA on September 18, 2023.  The TCA applies to Schwartz’s claims against TriNet. 

 

            D.  Schwartz fails to establish that the agreement is unconscionable

 

            A written agreement to submit a controversy to arbitration is valid, enforceable, and irrevocable, “save upon such grounds as exist at law or in equity for the revocation of any contract.”  (9 U.S.C. § 2; see also Code of Civ. Proc., § 1281.)  “Unconscionability provides such grounds.”  (Ramirez v. Charter Communications, Inc. (July 15, 2024, No. S273802) __ Cal.5th __ [2024 WL 3405593, at *3] (“Ramirez”).)

 

            As our Supreme Court recently summarized:  “The general principles of unconscionability are well established. A contract is unconscionable if one of the parties lacked a meaningful choice in deciding whether to agree and the contract contains terms that are unreasonably favorable to the other party.  Unconscionability has both a procedural and a substantive element.  The party resisting enforcement of an arbitration agreement has the burden to establish unconscionability.”  (Ramirez, supra, at p. *3.) 

 

            “Procedural unconscionability ‘addresses the circumstances of contract negotiation and formation, focusing on oppression or surprise due to unequal bargaining power.’  This element is generally established by showing the agreement is a contract of adhesion, i.e., a standardized contract which, imposed and drafted by the party of superior bargaining strength, relegates to the subscribing party only the opportunity to adhere to the contract or reject it.  Adhesion contracts are subject to scrutiny because they are “not the result of freedom or equality of bargaining.” (Ibid.) However, they remain valid and enforceable unless the resisting party can also show that one or more of the contract's terms is substantively unconscionable or otherwise invalid.”  (Ibid.)

 

            “Substantive unconscionability looks beyond the circumstances of contract formation and considers the fairness of an agreement's actual terms, focusing on whether the contract will create unfair or one-sided results. Substantively unconscionable contractual clauses reallocate risks in an objectively unreasonable or unexpected manner.”  (Ibid.)

 

            “Both procedural and substantive elements must be present to conclude a term is unconscionable, but these required elements need not be present to the same degree. Courts apply a sliding scale analysis under which the more substantively oppressive a term, the less evidence of procedural unconscionability is require to come to the conclusion that the term is unenforceable, and vice versa.  Whether a contract is fair or works unconscionable hardship is determined with reference to the time when the contract was made and cannot be resolved by hindsight by considering circumstances of which the contracting parties were unaware.”  (Ibid (citations omitted).)

 

                        i.  Low degree of procedural unconscionability established

 

            “Ordinary contracts of adhesion, although they are indispensable facts of modern life that are generally enforced, contain a degree of procedural unconscionability even without any notable surprises, and bear within them the clear danger of oppression and overreaching.  Courts must be particularly attuned to this danger in the employment setting, where economic pressure exerted by employers on all but the most sought-after employees may be particularly acute. Thus, although adhesion alone generally indicates only a low degree of procedural unconscionability, the potential for overreaching in the employment context warrants close scrutiny of the contract's terms.”  (Ramirez, supra, at p. *4].)

 

            The TCA is a contract of adhesion.  TriNet provides the TCA to the worksite employee, who may review and accept the TCA and agree to abide by it.  (C. Thompson Dec., ¶5.)  The employee is not allowed to negotiate and the agreement it is presented on a take it or leave it basis.  (Id.; Ycasas Dec., ¶7; Schwartz Dec., ¶10.)  However, the employee, including Schwartz, did not have to review or execute it by any deadline and he could return to the TCA to review it at any time.  (C. Thompson Dec., ¶11.) 

 

            Schwartz testifies he did not consult an attorney prior to executing the TCA, nor was he advised to do so.  The failure to advise Schwartz to consult an attorney does not qualify as procedural unconscionability. Schwartz was not discouraged or prevented from consulting an attorney and he had time to consult one.  (C. Thompson Dec., ¶11.) 

 

            Schwartz fails to substantiate his claim of “surprise.” Schwartz argues the TCA was “buried within a totally different agreement.”  (Opposition, 15:4.)  The manner in which the TCA is presented to employees is described by TriNet’s Director of Global Security, Thompson.  After completing the security profile, the employee “is next presented with the full text of the TCA for the WSE’s review and acceptance.  Prior to acceptance, each WSE is given the option to enter a personal email address if he/she wants a copy of the TCA to also be sent to his/her personal email in addition to his/her work email, which is entered into the TriNet Platform by the client at the time the employee is hired by the worksite employer (here OTTera). Also prior to acceptance, the WSE is provided with acknowledgement language in bold wherein by his/her acceptance the WSE confirms that he/she has read and understands the content of the TCA, including, but not limited to, the DRP.”  (C. Thompson Dec., ¶9.)

 

            Nothing in the process described by Thompson would support a finding of surprise.  Schwartz fails to submit any evidence refuting Thompson’s description of how the TCA was presented to him. 

 

            In addition, although the TCA is an employment agreement and Schwartz was an employee, he was a highly “sought after employee,” who was actively recruited to be the Chief Revenue Officer at OTTera, Inc., an executive  (Complaint, ¶17.)  Thus, the imbalance of power that ordinarily exists between an employer and employee and the economic pressure that an employer can exert on an employee are less of a concern here.  (Ramirez, supra, at p. *4].)

 

            There is therefore a low degree of procedural unconscionability based on Defendant TriNet’s use of a contract of adhesion.  There must therefore be a high degree of substantive unconscionability to deny enforcement of the TCA. 

 

                        ii.  TCA is not substantively unconscionable

 

            Substantive unconscionability is considered only after evaluating procedural unconscionability.  (Ramirez, supra, at p.*4].)  The focus of the analysis is whether the agreement imposes terms that are overly harsh, unduly oppressive, so one-sided as to shock the conscience, or unfairly one-sided.  (Id.at *5.)  “A party cannot avoid a contractual obligation merely by complaining that the deal, in retrospect, was unfair or a bad bargain.  Not all one-sided contract provisions are unconscionable…The ultimate issue in every case is whether the terms of the contract are sufficiently unfair, in view of all relevant circumstances, that a court should withhold enforcement.”  (Id.)

 

            Schwartz argues the TCA is substantively unconscionable on the following grounds:  (1) the agreement is unconscionably broad in scope; (2) the agreement is unconscionably broad in duration; (3) the agreement lacks mutuality as it requires the employee to arbitrate any claims against an employee, officer or director of TriNet or of a TriNet customer but it does not require any of these intended beneficiaries to arbitrate their claims against the employee; and (4) the TCA contains an unenforceable PAGA waiver. 

 

            The agreement is not impermissibly broad in scope.  Schwartz relies on Cook v. University of Southern California (2024) 102 Cal.App.5th 312 to support his claim that the TCA is overly broad.  However, the arbitration provision in Cook is distinguishable.  In Cook, the arbitration agreement encompassed “all claims, whether or not arising out of Employee’s University employment, remuneration or termination….”  (Cook, supra, 102 Cal.App.5th at 321.)  The defendant in Cook also conceded that “the scope of the agreement—as written—is unconscionably broad and must be construed to mean other than what it plainly states to avoid unreasonable results.”  (Id.)

 

            The DRP is limited to “any dispute arising out of or relating to your co-employment with TriNet and/or arising out of or relating to your employment with your company, and for any dispute with an employee, officer, or director of TriNet or a TriNet customer.”  (C. Thompson Dec., ¶10, Ex. A, Section 8, p. 5 of 8.)  The DRP is therefore not impermissibly broad in scope and is reasonably limited to disputes arising out of Schwartz’s employment relationship with OTTera, Inc. and Trinet Group, Inc.  Defendant TriNet Group also does not concede that the DRP as written would be unreasonable. 

 

            The agreement is not unreasonable in duration.  Again, Schwartz relies on Cook to support his position that the duration of the agreement is unreasonable.  However, Cook is distinguishable for several reasons.  In Cook, the defendant made no arguments that could be considered for the first time on appeal as to the issue of unreasonable duration.  (Cook, supra, 102 Cal.App.5th at 325.) 

 

            Substantively, the Court of Appeal rejected the defendant’s argument.  The arbitration agreement in Cook would survive the employee’s termination and could “only be revoked or modified in a written document that expressly refers to the ‘Agreement to Arbitrate Claims’ and is signed by the President of the University.”  (Cook, supra, 102 Cal.App.5th at 325.)  In finding the arbitration agreement was not terminable at will within a reasonable time, Cook focused on the arbitration agreement’s requirement that the parties’ enter into a new written agreement expressly revoking the arbitration agreement signed by the President of the University.  “[T[he inclusion of this language…shows the parties did not contemplate that the arbitration agreement would be terminable at will.”  (Cook, supra, 102 Cal.App.5th at 326.) 

 

            Although the DRP states it “will survive the termination of the employment relationship,” there is no provision that it will endure until the parties agree formally to its revocation or modification.  Moreover, because the DRP is limited to claims arising out of the employment relationship, the duration of the DRP is also limited by virtue of applicable statutes of limitation and the conclusion of the employment relationship.  Cook is therefore factually distinguishable.

 

             The agreement does not lack mutuality.  Schwartz argues the DRP does not require the third-party beneficiaries to arbitrate their disputes with employees arising from the employment relationship.  However, TriNet is not a third party beneficiary but a named signatory to the agreement and based on the language of Section 8 of the TCA, the arbitration agreement is not limited to an employee’s claims against TriNet.  The agreement applies to any and all claims arising from the employment relationship and its scope is not limited to claim brought by the employee against either employer.  (C. Thompson Dec., Ex. 1, Section 8.)  The agreement therefore does not lack mutuality as between Schwartz and moving party TriNet. 

 

            As to third party beneficiaries identified in the agreement (TriNet’s subsidiaries, the
Tri-Net co-employer, an employee, officer, or director of TriNet or of a TriNet customer), the agreement does not lack mutuality due to existing law.  “A nonsignatory can be compelled to arbitrate when a preexisting relationship existed between the nonsignatory and one of the parties to the arbitration agreement, making it equitable to compel the nonsignatory to arbitrate as well.  Additionally, a nonsignatory can be compelled to arbitrate when it is suing as a third-party beneficiary of the contract containing the arbitration clause.”  (JSM Tuscany, LLC v. Superior Court (2011) 193 Cal.App.4th 1222, 1240.) 

 

            The named third parties here are the TriNet customer or co-employer (OTTera, Inc.) and an employee, officer or director of TriNet or of a TriNet customer (employees of TriNet or OTTera, Inc.).  A preexisting relationship existed between signatory TriNet and the named third party beneficiaries:  OTTera, Inc., the employees of TriNet and the employees of OTTera, Inc.  TriNet HR III, the company hired by OTTera, Inc. for human resources services, is a subsidiary of TriNet.  (C. Thompson Dec., ¶2; Ycasas Dec., ¶6.)  If any of these third party beneficiaries sued Schwartz for claims arising from the employment relationship, Schwartz could compel them to arbitrate those claims pursuant to the DRP based on equitable estoppel. 

 

            Schwartz fails to establish that the DRP lacks mutuality as to either TriNet or the named third party beneficiaries.  The DRP is not unconscionable based on lack of mutuality.

 

            The agreement’s PAGA waiver is unenforceable.  The PAGA waiver located in section 8(d) of the DRP is unenforceable.  Viking River left intact Iskanian’s principal rule prohibiting employers from imposing a waiver of an employee's right to bring a ‘representative’ PAGA claim in any forum, either in its individual or nonindividual sense.”  (DeMarinis v. Heritage Bank of Commerce (2023) 98 Cal.App.5th 776, 787.) 

 

            However, the PAGA waiver can be severed from the rest of the agreement and the remainder of the DRP enforced.  “If the court as a matter of law finds the contract or any clause of the contract to have been unconscionable at the time it was made the court may refuse to enforce the contract, or it may enforce the remainder of the contract without the unconscionable clause, or it may so limit the application of any unconscionable clause as to avoid any unconscionable result.”  (Civ. Code, section 1670.5, subd. (a); Adolph v. Uber Technologies (2023) 14 Cal.5th 1104, 1124.)  The PAGA waiver is not grounds to deny the motion to compel arbitration. 

 

            E. Request for Joinder by Defendants OTTera, Inc., Stephen L. Hodge, Steve Rifkin and Craig McEldowney

 

            Joinder Defendants join TriNet’s motion.  Defendants argue in their joinder that they are entitled to compel arbitration of Schwartz’s claims against them pursuant to the DRP based on their status as third party beneficiaries. Defendant’s request for joinder is granted.

 

            Defendants are expressly named third party beneficiaries of the DRP.  Defendant OTTera, Inc. is a “co-employer” and client of TriNet as defined under the TCA.  (C. Thompson Dec., ¶10, Ex. A, Sections 1 and 9, pp. 1 and 2 of 8.)  Defendants Hodge, Rifkin and McEldowny are all being sued for acts carried out as employees of OTTera, Inc. (Complaint, ¶¶7-9.)  DRP expressly names co-employers and clients of TriNet as third party beneficiaries, as well as the employees of co-employers and clients of TriNet.  (C. Thompson Dec., ¶10, Ex. A, Sections 1 and 9, pp. 1 and 2 of 8.) 

 

            Plaintiff has also alleged that each Defendant is the alter ego of the other Defendants.  “[U]nder equitable estoppel principles and in appropriate factual circumstances, a signatory to a[n] agreement containing an arbitration clause may be compelled to arbitrate its claims against a nonsignatory when the relevant causes of action rely on and presume the existence of the contract.”  (Boucher v. Alliance Title Co. Inc. (2005) 127 Cal.App.4th 262, 269; see also Rowe v. Exline (2007) 153 Cal.App.4th 1276, 1287 (plaintiff’s claims against nonsignatory directors who were sued as alter egos of corporation were subject to arbitration based on arbitration provision contained in plaintiff’s agreement with corporation; plaintiff could not sue directors as alter egos of corporation then at the same time disclaim their right to compel arbitration pursuant to arbitration agreement with corporation.) 

 

            Joinder Defendants therefore establish standing to compel arbitration pursuant to the DRP and grounds to join TriNet’s Motion to Compel Arbitration.  Joinder Defendants’ request for joinder is granted. 

 

            F.  Request to stay or dismiss action

 

            TriNet and Joinder Defendants ask that the Court stay or dismiss the action upon granting the motion to compel arbitration.  There is no authority to dismiss the action.  The action is stayed pending completion of arbitration pursuant to Code of Civil Procedure, section 1281.4.

 

III.  Conclusion

 

            Defendant TriNet Group, Inc.’s Motion to Compel Arbitration is granted pursuant to the TCA and DRP acknowledged and accepted by Plaintiff on September 18, 2023, 9 U.S.C §3 and Code of Civil Procedure, section 1281.2.  The action is stayed pending completion of arbitration pursuant to Code of Civil Procedure, section 1281.4. 

 

            Joinder Defendants’ request for joinder is granted.  Plaintiff’s claims against Joinder Defendants are also ordered to arbitration.