Vo

I. FACTS AND PROCEDURAL BACKGROUND

Prior to beginning his employment with TCU in 2020, Vo signed an employment arbitration agreement (the agreement). Pursuant to the agreement, both parties agreed “to submit to mandatory binding arbitration any dispute, claim or controversy arising out of or relating to Employee’s employment with the Company.” The agreement defined “[a]rbitrable [c]laims” as claims for discrimination, harassment, unpaid wages, wrongful termination, and breach of contract, among others. The agreement excluded any claims not subject to a contractual requirement of mandatory binding arbitration by law, such as claims for workers’ compensation benefits and unemployment compensation. The parties agreed that a neutral arbitrator from JAMS would administer any arbitrations pursuant to its employment arbitration rules and procedures available at the JAMS website. The incorporated JAMS rules and procedures were not attached to the agreement. By signing the agreement, the parties acknowledged they read and understood the agreement and entered into it freely and voluntarily. While employed with TCU, Vo contracted COVID-19 and developed long-term health issues, which…