Nunez

FACTS AND PROCEDURAL HISTORY

Cycad hired Nunez as a gardener in 2018. It required him to sign the Agreement, which mandates arbitration of “all disputes between Employee and Company relating, in any manner whatsoever, to the employment or termination” of the employee. It encompasses wage, tort, statutory, discrimination, and contract claims. It limits discovery to “three depositions and an aggregate of thirty (30) discovery requests of any kind, including sub-parts.” Nunez filed suit on August 27, 2019. 1 Cycad answered the complaint and initiated discovery. In April 2020, Cycad’s attorney

1 The complaint is not in our record. Cycad states that Nunez asserts claims for battery; assault; violation of the Ralph Civil Rights Act of 1976 (Civ. Code, § 51.7); violation of the Tom Bane Civil Rights Act (Civ. Code, § 52.1); failure to provide a safe workplace; violation of right to protection from bodily harm; violation of the Whistleblower Protection Act; violations of Labor Code sections 201–203, 1198.5, and 6310; infliction of emotional distress; and wrongful termination in violation of public policy. Defendant Bassam Alghanim joined Cycad’s motion to arbitrate but did not appeal.…