Brown

BACKGROUND

The facts and allegations in this appeal are taken from the complaint and the papers submitted in connection with the motion to compel arbitration.

2 A. Complaint On January 10, 2012, plaintiff, Peggy Brown, filed this action. The complaint alleged as follows. On or about February 19, 2002, plaintiff commenced employment with defendant Automobile Club of Southern California (Auto Club) as a “claims representative.” At the time of hire, plaintiff was around 48 years old. Throughout her employment, plaintiff received written performance reviews rating her as an excellent employee. She also received pay raises. In or around October 2005, plaintiff was promoted to the “Special Investigative Unit” in Los Angeles. In 2007, she was transferred to the Valencia office. She continued to receive excellent performance reviews. In March 2010, plaintiff received her last written performance review, which indicated she “‘fully achieves’” the objectives of her job and praised her for “‘assist[ing] her teammates’” and for “‘the level of maturity she brings.’” Beginning in late 2009, plaintiff requested intermittent time off under the state Moore–Brown–Roberti Family Rights Act…