Judge: Gail Killefer, Case: 22STCV30655, Date: 2023-02-23 Tentative Ruling

Case Number: 22STCV30655    Hearing Date: February 23, 2023    Dept: 37

HEARING DATE:                 February 23, 2023    

 

CASE NUMBER:                  22STCV30655

 

CASE NAME:                        Isador Martin, et al. v. Nusret BH LLC, et al.

 

MOVING PARTY:                Defendant, Nusret BH LLC, dba Nusr-Et Steakhouse Beverly Hills

 

OPPOSING PARTIES:          Plaintiffs, Isador Martin, Khadijah Betts, Ryan Casper, Viridiana Mendez, Cynthia Mercado, Daniel Miranda, Christopher Olivera, Marina Ortiz, Melissa Preciado, Lily Reynaldo, Nekay Sandoval, and Gerardo Gutierrez Valenzuela

 

TRIAL DATE:                        Not Set.

 

PROOF OF SERVICE:          OK

                                                                                                                                                           

MOTION:                               Defendant’s Motion to Compel Arbitration and for a Stay of Proceedings

 

OPPOSITION:                       February 8, 2023

 

REPLY:                                  February 15, 2023

                                                                                                                                                           

TENTATIVE:                         Defendant’s motion to compel arbitration is granted. Defendant is to give notice.

                                                                                                                                                           

Background

This action arises out of the employment of Plaintiffs Isador Martin, Khadijah Betts, Ryan Casper, Viridiana Mendez, Cynthia Mercado, Daniel Miranda, Christopher Olivera, Marina Ortiz, Melissa Preciado, Lily Reynaldo, Nekay Sandoval, and Gerardo Gutierrez Valenzuela (“Plaintiffs”) in various positions with Defendants Nusret BH LLC, dba Nusr-Et Steakhouse Beverly Hills, its parent entity Nusret US, Inc., and individual defendant, owner and operator, Nusret Gokce (“Defendants”). Plaintiffs allege they were hired by Defendants in or around 2021 and worked for Defendants for various lengths of time. Plaintiffs allege Defendants violated wage and hour laws in failing to pay overtime wages, provide meal and rest breaks, provide accurate wage statements, and reimburse business expenses, among other violations.

 

Plaintiffs’ operative Complaint alleges the following causes of action: (1) failure to pay wages and overtime in violation of Labor Code §§ 1194, 1197, (2) failure to provide meal breaks in violation of Labor Code § 226.7, (3) failure to provide rest breaks in violation of Labor Code § 226.7, (4) failure to reimburse business expenses in violation of Labor Code § 2802, (5) failure to furnish accurate wage statements in violation of Labor Code § 226, (6) waiting time penalties under Labor Code § 203—all Plaintiffs except Cynthia Mercado, (7) conversion, and (8) unfair business practices.

 

Defendant now moves to compel arbitration. Plaintiffs oppose the motion.

 

Evidentiary Objections

Plaintiffs’ Objections to Defendant’s Evidence

Overruled: 1

 

Discussion

I.                   Legal Standard

“California law reflects a strong public policy in favor of arbitration as a relatively quick and inexpensive method for resolving disputes.  To further that policy, Code of Civil Procedure, section 1281.2 requires a trial court to enforce a written arbitration agreement unless one of three limited exceptions applies.  Those statutory exceptions arise where (1) a party waives the right to arbitration; (2) grounds exist for revoking the arbitration agreement; and (3) pending litigation with a third party creates the possibility of conflicting rulings on common factual or legal issues.”  (CCP § 1281.2; Acquire II, Ltd. v. Colton Real Estate Group (2013) 213 Cal.App.4th 959, 967.) 

 

Similarly, public policy under federal law favors arbitration and the fundamental principle that arbitration is a matter of contract and that courts must place arbitration agreements on an equal footing with other contracts and enforce them according to their terms.  (AT&T Mobility LLC v. Concepcion (2011) 563 U.S. 333, 339.)

 

In deciding a motion or petition to compel arbitration, trial courts must first decide whether an enforceable arbitration agreement exists between the parties and then determine whether the claims are covered within the scope of the agreement.  (Omar v. Ralphs Grocery Co. (2004) 118 Cal.App.4th 955, 961.)  The opposing party has the burden to establish any defense to enforcement.  (Gatton v. T-Mobile USA, Inc. (2007) 152 Cal.App.4th 571, 579 [“The petitioner ... bears the burden of proving the existence of a valid arbitration agreement and the opposing party, plaintiffs here, bears the burden of proving any fact necessary to its defense.”].)

 

II.                Existence of an Arbitration Agreement

A motion to compel arbitration or stay proceedings must state verbatim the provisions providing for arbitration or must have a copy of them attached.  (Cal. Rules of Court, rule 3.1330.)

A party may demonstrate express acceptance of the arbitration agreement in order to be bound (e.g., Mago v. Shearson Lehman Hutton Inc. (9th Cir. 1992) 956 F.2d 932 [agreement to arbitrate included in job application]; Nghiem v. NEC Electronic, Inc. (9th Cir. 1994) 25 F.3d 1437 [agreement to arbitrate included in handbook executed by employee]; Lagatree v. Luce, Forward, Hamilton & Scripps (1999) 74 Cal. App. 4th 1105 [88 Cal. Rptr. 2d 664] [employer may terminate employee who refuses to sign agreement to arbitrate]) or implied-in-fact in fact acceptance (Asmus v. Pacific Bell (2000) 23 Cal. 4th 1, 11 [96 Cal. Rptr. 2d 179, 999 P.2d 71] [implied acceptance of changed rules regarding job security]; DiGiacinto v. Ameriko-Omserv Corp. (1997) 59 Cal. App. 4th 629, 635 [69 Cal. Rptr. 2d 300] [implied acceptance of changed compensation rules]).  (Craig v. Brown & Root (2000) 84 Cal.App.4th 416, 420 (Craig).) 

“A signed agreement is not necessary, however, and a party’s acceptance [of an agreement to arbitrate] may be implied in fact….”  (Pinnacle Museum Tower Ass’n v. Pinnacle Market Dev. (US), LLC (2012) 55 Cal.4th 223, 23 (Pinnacle), cited in Pet. Mem. 6.)  “An arbitration clause within a contract may be binding on a party even if the party never actually read the clause.”  (Ibid.) “The content of a writing may be proved by otherwise admissible secondary evidence,” except when “a genuine dispute exists concerning material terms of the writing,” or admitting the secondary evidence “would be unfair.” (Evidence Code § 1521, subd. (a).) A party seeking to introduce secondary evidence to prove the contents of a lost writing must demonstrate that “ “a bona fide and diligent search has been unsuccessfully made for it”” (Dart Industries, Inc. v. Commercial Union Ins. Co. (2002) 28 Cal.4th 1059, 1068, quoting Folsom Executors v. Scott (1856) 6 Cal.4th 460, 461.)

 

Defendants argue that Plaintiffs must be compelled to arbitrate because Plaintiffs executed arbitration agreements as they began their employment agreeing to arbitrate all disputes they had with Defendants. (Motion, 2-3.)

 

Each Plaintiff signed a document in 2021 titled “Mutual Agreement to Arbitrate Claims” (“Agreement”)(Avci Decl., ¶12, Exh. B). The Arbitration Agreement provides as follows:

 

“...This Mutual Agreement to Arbitrate Claims (the "Agreement") is made and entered into as of the date it is fully executed by and between Nusret BH, LLC (the "Employer" or "Nusret") and the individual employee whose name and signature appears below (the "Employee"). The Employer and Employee are referred to collectively as the "Parties." The Federal Arbitration Act (9 U.S.C. § 1 et seq.) applies to this Agreement. If for any reason the Federal Arbitration Act does not apply, this Arbitration Provision shall be governed in accordance with the provisions of the California Arbitration Act. (California Code of Civil Procedure, Section 1280 et seq., including the provisions of California Code of Civil Procedure Section 1283.05). ALL DISPUTES COVERED BY THIS AGREEMENT WILL BE DECIDED BY A SINGLE ARBITRATOR THROUGH FINAL AND BINDING ARBITRATION AND NOT BY WAY OF COURT OR JURY TRIAL.

 

 1. CLAIMS COVERED BY THIS AGREEMENT. This Agreement is intended to be as broad as legally permissible, and, except as it otherwise provides, applies to all claims or controversies, past, present, or future, that otherwise would be resolved in a court of law or before a forum other than arbitration, including without limitation, claims or disputes arising out of or related to the application and selection for employment, employment relationship, and termination of the employment relationship. Except as it otherwise provides, this Agreement applies to any claims or disputes that the Company may have against You or that You may have against any of the following (1) the Company; (2) its officers, directors, employees, or agents in their capacity as such or otherwise; (3)the Company's parent, subsidiary, and affiliated entities and their officers, directors, employees, or agents in their capacity as such or otherwise, (4) the Company's benefit plans or the plans' sponsors, fiduciaries, administrators, affiliates and agents, and/or (5) all successors and assigns of any of them.

Except as it otherwise provides, this Agreement applies, without limitation, to claims based upon or related to discrimination, harassment, retaliation, defamation (including post-employment defamation or retaliation), breach of a contract or covenant, fraud, negligence, breach of fiduciary duty, wages, misclassification, minimum wage and overtime or other compensation or any monies claimed to be owed, meal breaks and rest periods, termination, whistleblowing, tort claims, common law claims, statutory claims, equitable claims, and claims arising under the Civil Rights Act of 1964, Americans With Disabilities Act, Age Discrimination in Employment Act, Pregnancy Discrimination Act, Family and Medical Leave Act, Fair Labor Standards Act, Employee Retirement Income Security Act (except for claims for employee benefits under any benefit plan sponsored by the Company and covered by the Employee Retirement Income Security Act of 1974), Affordable Care Act, Genetic Information Non-Discrimination Act, Uniformed Services Employment and Reemployment Rights Act, Worker Adjustment and Retraining Notification Act, Older Workers Benefits Protection Act of 1990, Occupational Safety and Health Act, Consolidated Omnibus Budget Reconciliation Act of 1985, Fair Credit Reporting Act, False Claims Act, Equal Pay Act, and any other state or local statutes or regulations addressing the same or similar subject matters, and all other federal, state, or local legal claims arising out of or relating to Your application, selection, employment, or the termination of employment (including without limitation torts and post-employment defamation or retaliation).

Except as it otherwise provides, this Agreement applies to any dispute, past, present, or future arising out of and/or related to the above, including claims that arose before the Parties executed this Agreement. However, this Agreement does not apply to litigation between Employee and Employer pending in a state or federal court or arbitration as of the date of your receipt of this Agreement including any class and/or collective action, for which you are already a member or potential member of the class or collective action. The Arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve any dispute relating to the validity, applicability, enforceability, unconscionability, or waiver of this Agreement. However, the preceding sentence does not apply to the "Class Action Waiver" below. Notwithstanding anything else in this Agreement or the AAA Employment Arbitration Rules and Mediation Procedures (discussed below), any dispute relating to the validity, applicability, enforceability, unconscionability or waiver of the Class Action Waiver may only be determined by a court and not an arbitrator. Nothing contained in this Agreement shall be construed to prevent or excuse Employee from using the Employer's existing internal procedures for resolution of complaints, and this Agreement is not intended to be a substitute for using such procedures.

...

3. ARBITRATION PROCEDURES. The arbitration will be administered by the American Arbitration Association (the "AAA"), pursuant to its Employment Arbitration Rules and Mediation Procedures (the "AAA Rules") applicable at the time the arbitration is commenced, including the AAA Optional Rules for Emergency Measures of Protection, with judgment on the award rendered by the arbitrator to be entered in any court having jurisdiction thereof. If the AAA Rules are inconsistent with the terms of this Agreement, the terms of this Agreement shall govern. A copy of the AAA Rules can be found online by going to www.adr.org. Employee may also obtain a copy of the AAA Rules by, either calling the American Arbitration Association at (800) 778-7879 or by contacting the Human Resources Department.

...

6. SELECTION OF ARBITRATOR. The matter shall be heard and be determined by one (1) neutral arbitrator who must be a practicing lawyer, mutually selected by the Parties, with at least ten (10) years of experience in employment law. In the event the Parties cannot agree on the selection of an arbitrator, one neutral arbitrator shall be appointed as provided in the AAA Rules. However, that arbitrator must be a practicing attorney with at least ten (10) years of experience in employment law or a retired state or federal judge from any jurisdiction.

 

7. MOTIONS. The arbitrator shall have jurisdiction to hear and rule on prehearing disputes and is authorized to hold prehearing conferences by telephone or in person, as the arbitrator deems necessary. The arbitrator may allow the filing of a dispositive motion if the arbitrator determines that the moving Party has shown substantial cause that the motion is likely to succeed and dispose of, or narrow, the issues in the case. The arbitrator shall have the authority to set deadlines for filing dispositive motions, and to set briefing schedules for any motions. The arbitrator shall have the authority to adjudicate any cause of action, or the entire claim, pursuant to a motion for summary adjudication and in deciding the motion, shall apply the substantive law applicable to the cause of action. Finally, in deciding any dispositive motion, the arbitrator shall have the authority to conduct independent legal research.

 

8. DISCOVERY. The AAA Rules regarding discovery shall apply to any arbitration conducted pursuant to this Agreement. The arbitrator shall decide all discovery disputes. Further, the arbitrator shall have the authority to determine which discovery mechanisms shall be utilized, but shall do so in furtherance of the Parties' intention that, by entering into this Agreement, they will gain the benefits of a speedy and less expensive dispute resolution procedure.

...

16. WAIVER. The Employer may waive its right to require Employee to arbitrate a Covered Claim initiated by Employee. However, the Parties agree that such a waiver shall not be deemed a waiver or relinquishment by Employer to enforce its rights against Employee in the future. Further, such waiver shall be limited to the specific Claim(s) at issue and shall not be construed as a general waiver of the requirement to arbitrate all other Covered Claims.

...

18. FEDERAL ARBITRATION ACT. Any arbitration conducted pursuant to this Agreement shall be governed and enforced by the Federal Arbitration Act (9 U.S.C. §§ l-16m the "FAA").

 

19. FEES AND COSTS. Employee shall be responsible for payment of AAA filing fees, provided that fees shall not exceed the maximum amount permitted by the rules of the AAA. Except as provided above. Employer shall be responsible for any remaining AAA fees and expenses and shall be responsible for the arbitrator's fees and expenses. To the maximum extent permitted by applicable law, each Party shall pay its own costs and attorney's fees, if any. However, if either Party prevails on a statutory claim which affords the prevailing Party attorney’s fees and costs, or if there is a written agreement providing for attorney's fees and costs, the arbitrator may award reasonable attorney' s fees and costs to the prevailing Party. Any dispute as to the reasonableness of any fee or cost shall be resolved by the arbitrator. Notwithstanding the foregoing, to the extent permitted by applicable law. Employee agrees that if Employee files a court action concerning a Covered Claim, or refuses to arbitrate a Covered Claim, the Employer shall be entitled to recover its costs including any applicable AAA costs and reasonable attorney’s fees incurred in enforcing the arbitration provisions of this Agreement.

...

25. VOLUNTARY AGREEMENT. BY EXECUTING THIS AGREEMENT, EMPLOYEE REPRESENTS THAT EMPLOYEE UNDERSTANDS THIS AGREEMENT AND FREELY AND VOLUNTARILY ENTERED INTO IT AFTER BEING PROVIDED AN ADEQUATE OPPORTUNITYTO FULLY REVIEW AND COMPREHEND IT AND SEEK THE ADVICE OF INDEPENDENT COUNSEL, WHICH THE EMPLOYEE HAS DONE TO THE EXTENT DESIRED.

...

27. CLASS AND COLLECTIVE ACTION WAIVER. This Agreement affects your ability to participate in class or collective actions. Both the Company and you agree to bring any dispute in arbitration on an individual basis only, and not on a class or collective basis on behalf of others. There will be no right or authority for any dispute to be brought, heard or arbitrated as a class or collective action, or as a member in any such class or collective proceeding ("Class Action Waiver"). Notwithstanding any other provision of this Agreement or the JAMS Rules, disputes regarding the validity, enforceability or breach of the Class Action Waiver may be resolved only by a civil court of competent jurisdiction and not by an arbitrator. In any case in which (1) the dispute is filed as a class or collective action and (2) a civil court of competent jurisdiction finds all or part of the Class Action Waiver unenforceable, the class or collective action to that extent must be litigated in a civil court of competent jurisdiction, but the portion of the Class Action Waiver that is enforceable shall be enforced in arbitration. You will not be retaliated against, disciplined or threatened with discipline as a result of your filing of or participation in a class or collective action in any forum. However, the Company may lawfully seek enforcement of this Agreement and the Class Action Waiver under the Federal Arbitration Act and seek dismissal of such class or collective actions or claims. The Class Action Waiver shall be severable in any case in which the dispute is filed as an individual action and severance is necessary to ensure that the individual action proceeds in arbitration.

Private attorney general representative actions brought on behalf of the state under the California Labor Code are not arbitrable, not within the scope of this Agreement and may be maintained in a court of law, but any claim on your own behalf as an aggrieved employee for recovery of underpaid wages (as opposed to representative claims for civil penalties) shall be arbitrable...”

(Motion, Avci Decl., Exh. B.)

 

The Agreement is signed by all Plaintiffs and Kristi Thompson on behalf of Nusret BH, LLC. (Avci Decl., Exh. B.) However, an arbitration agreement need not include both parties’ signatures to be enforceable. (Serafin v. Balco Properties, Ltd. LLC (2015) 235 Cal.App.4th 165, 176 [existence of agreement to arbitrate can be confirmed through evidence of the parties’ conduct.]) Thus, Defendant contends the Agreement encompasses all of Plaintiffs’ claims, and necessarily incorporates the Federal Arbitration Act as the parties agreed that the FAA governs the signed Agreement. (Motion, 3-6.) Defendant further argues the Agreement “affects commerce because Defendant’s business activities regularly and consistently involve commerce... Here, Defendant’s operations regularly involve the purchase and use of food, equipment, and other items and supplies from numerous suppliers and distributors, which in turn are transported across state lines for delivery and sale.” (Motion, 7-8.)

 

Further, Defendant contends that the Agreement “explicitly delegates” authority to the arbitrator to determine the applicability and enforceability of this Agreement. (Motion, 8-9; citing AT&T Tech. v. Communications Workers of America, (1986) 475 U.S. 643, 649.) Thus, Defendant contends the question of “whether the Agreement is a valid contract” should be left to the arbitrator to determine, but even if the “Court nevertheless does so,” the court should still find the Agreement to be a valid contract. (Motion, 9-10.) Defendant points to the mutual assent by the parties, and further contends Plaintiffs’ wage and hour claims “are squarely within the scope of the Agreement, which covers all disputes with respect to Plaintiff’s [sic] employment.” (Motion, 10-13.) Further, Defendant argues that the Plaintiffs have “unequivocally waived any right to participate in any collective actions,” and that the Agreement “clearly precludes Plaintiffs’ participation in any collective action and requires arbitration of their individual claims.” (Motion, 13-14.)

 

In opposition, Plaintiffs contends that arbitration must not be compelled because a valid arbitration agreement does not exist. (Opposition, 3-7.) Plaintiffs contend they “signed opt-out letters” and that Defendant “must now establish by a preponderance of the evidence that Plaintiffs’ opt-out revocations are invalid.” (Opp., 5.) The court here notes Plaintiffs have failed to attach as exhibits their opt-out letters which were purportedly received by Defendant’s counsel. Plaintiffs further argue that under the Uniform Electronic Transactions Act (UETA), “Defendant’s motion seeks to compel arbitration based on purported electronic signatures,” but “Defendant does not provide evidence to establish that Plaintiffs ever agreed” to execute the Agreement “by electronic means.” (Opp., 5-6.)

 

In reply, Defendants contend correctly the Agreement “explicitly informed Plaintiffs their electronic signature would have the same legal effect of a handwritten signature” and that “Plaintiffs signed the Arbitration Agreement” regardless. (Reply, 3-4.) The court also notes that no authentication of an opposing party’s signature is required as a preliminary matter in moving to compel arbitration. (Ruiz v. Moss Bros. Auto Group, Inc. (2014) 232 Cal.App.4th 836, 846.)

 

Thus, the court agrees with Defendant that Plaintiffs have failed to meet their burden of producing admissible evidence to challenge the authenticity of the Agreement.

 

While Plaintiffs point to the UETA, their opt-out letters, and an unsigned declaration submitted by Defendant, Defendant has remedied the unsigned declaration by submitting a dated and signed declaration in 24 hours, and Plaintiffs have failed to explain how their signatures could not be enforced here, or provide opt-out letters to question the validity of the Agreement. More importantly, Plaintiffs fail to provide admissible evidence, or point to relevant authority, to show that the FAA does not govern these claims. Thus, the court finds the FAA governs the Plaintiffs’ claims, given that the nature of Defendants’ operations affects interstate commerce.

 

For these reasons, the court finds that an enforceable agreement to arbitrate exists between the parties.

 

III.             Defenses to Arbitration

Plaintiff argues that in the event it is found that a valid agreement to arbitrate exists, arbitration should still not be compelled because the arbitration agreements are both procedurally and substantively unconscionable, do not meet the Armendariz factors, and because the Agreement does not implicate the Federal Arbitration Act. (Opposition, 3-15.)

 

A.     Unconscionability

Pursuant to Armendariz v. Foundation Health Psychcare Services, Inc. (2000) 24 Cal.4th 83, 114 both procedural and substantive unconscionability must be present in order for a court to exercise its discretion to refuse to enforce a valid arbitration agreement.

 

Plaintiffs argue that the arbitration agreement violates the Armendariz factors as it is an adhesion contract, requires confidentiality, purportedly restricts recoverable fees and costs, requires Plaintiffs to pay arbitration costs, and is unconscionable as it fails to incorporate the AAA Rules. (Opposition, 6-14.)

 

With regards to procedural unconscionability, the court agrees with Defendant that Plaintiffs cannot claim unfair surprise with regards to an alleged failure to provide notice as the document stands alone with several statements regarding the intent of the parties to arbitrate in emphasis. (Reply, 4-5.) “Plaintiffs do not argue in their opposition that they were lied to, placed under duress, manipulated into signing the Arbitration Agreement, or otherwise subjected to a surprise or other sharp practices.” (Id.) Defendant further contends “there is no restriction on remedies to Plaintiffs nor are they burdened with the cost of arbitration,” and “Plaintiffs concede that confidentiality by itself is not substantively unconscionable if not written too broadly,” which Defendant argues the confidentiality provision is not. (Reply, 6-7.) Arbitration agreements that apply to both parties equally are generally not substantively unconscionable. (Sanchez v. CarMax Auto Superstores Cal., LLC (2014) 224 Cal.App.4th 398, 403-404.)  

 

Further, the court agrees with Defendant the Agreement specifically provides for a neutral provider under AAA Rules, provides for sufficient discovery consistent with AA Rules, provides for a written decision, and does not require Plaintiffs to pay arbitration expenses. (Motion, 17-20.) The court further agrees with Defendant that the Agreement sufficiently incorporates the AA Rules by reference, and specifically gave Plaintiffs the opportunity to review the AAA Rules. (Reply, 6-7.)

 

Lastly, Plaintiffs allege the Agreement violates Labor Code § 432.6, as “Plaintiffs were forced to sign the arbitration agreement as a condition of their employment” and is therefore an adhesive contract in violation of that section. (Opposition, 4-5.)

 

Labor Code § 432.6 prohibits employers from requiring arbitration of claims for violation of FEHA or the Labor Code as a condition of employment or continued employment, even if the employee can opt out of the agreement or receives a benefit by accepting the agreement. (Lab. Code § 432.6(a).) In addition, Lab. Code § 432.6 prohibits an employer from threatening, retaliating, or discriminating against or terminating an applicant or employee because of a refusal to agree to arbitration. (Lab. Code § 432.6(a).) However, the law also states that it is not intended to invalidate a written arbitration agreement that is enforceable under the FAA. (Lab. Code § 432.6(f).) As this court has already found the Agreement to be enforceable under the FAA, the court now disregards this contention.

 

The court agrees with Defendant. Plaintiffs point to no authority, and the court is aware of none, in support of their contentions that the Agreement was both procedurally and/or substantively unconscionable. Further, Plaintiffs have failed to satisfy their burden of showing the Agreement does not implicate the Federal Arbitration Act, and have further failed to show how the Agreement is in violation of section 432.6. Lastly, Plaintiffs fail to show how the Agreement does not incorporate the necessary AAA Rules, or failed to provide notice to Plaintiffs of the fact that the document they signed was an Arbitration Agreement. Thus, Defendant’s arbitration agreements with Plaintiffs are not procedurally and/or substantively unconscionable, are enforced under the Federal Arbitration Act, and are valid as an agreement between the parties to arbitrate the claims which form the bases of Plaintiffs’ causes of action.

Thus, Defendant’s motion to compel arbitration is granted.

 

Conclusion

Defendant’s motion to compel arbitration is granted. Defendant is to give notice.