MUTUAL AGREEMENT TO ARBITRATE DISPUTES
This Mutual Agreement to Arbitrate Disputes (“Agreement”) is made and entered into by and between Jewels by Park Lane, Inc. (the “Company”) and the undersigned “Contractor”. The Company and the Contractor are collectively referred to herein as the “Parties”.
1. Agreement to Arbitrate. Except as stated herein, the Company and the Contractor mutually and voluntarily agree that any claim, complaint, or dispute that arises out of or relates in any way to the Parties’ relationship, whether based in contract, tort, statute, or any other legal theory, shall be submitted to binding arbitration administered by the American Arbitration Association (“AAA”). Unless otherwise required under applicable state law, the arbitrator will be the sole determiner of any disputes regarding arbitrability. Although Contractor is not an employee of the Company, the parties agree the arbitration shall be conducted in accordance with the AAA’s “Employment Arbitration Rules and Mediation Procedures” (the “AAA Rules”), unless those rules conflict with the procedures set forth in this Agreement. A copy of the AAA Rules is available at their website, https://www.adr.org, or upon request from management. The Parties may mutually agree to use the services of a different provider or any other arbitration rules and procedures.
2. Federal Arbitration Act: This Agreement is entered into under the Federal Arbitration Act (“FAA”) and shall be interpreted and construed in accordance with the law and procedures developed under that statute. The Company and Contractor agree the FAA applies to this agreement. In the event a court of law denies either Contractor or Company’s motion to compel arbitration, Contractor and Company agree any trial court proceedings shall be stayed under 9 U.S.C. § 16 when an interlocutory appeal of the order denying the motion to compel arbitration is sought by any party, regardless of whether the proceeding pending in state or federal court.
3. Covered Claims. This Agreement covers all grievances, disputes, claims, or causes of action under applicable federal, state or local laws, arising out of Contractor’s contractual relationship with the Company and the termination thereof, including claims Contractor may have against the Company or against its owners, officers, directors, supervisors, managers, Contractors, or agents in their capacity as such or otherwise, or that the Company may have against Contractor. The claims covered by this Agreement include, to the extent applicable, but are not limited to, claims for breach of any contract or covenant (express or implied), tort claims, claims for wrongful termination (constructive or actual) in violation of public policy, claims for discrimination, retaliation, or harassment, equitable claims, and claims for violation of any federal, state, or other governmental law, statute, regulation, or ordinance. The Parties to this Agreement specifically agree that all claims under the California Labor Code and claims deriving therefrom, if applicable, shall be subject to this Agreement. The Company and Contractor agree that arbitration is the exclusive remedy for all disputes covered by this Agreement. This includes any such claims against the Company’s affiliates, subsidiaries, parents, related entities, owners, directors, officers, managers, Contractors, or agents.
4. Claims Not Covered. To the extent applicable, this Agreement does not cover: (i) claims for sexual harassment or sexual assault arising on or after March 3, 2022; (ii) administrative claims arising under the National Labor Relations Act that must be brought before the National Labor Relations Board; (iii) administrative claims for medical and disability benefits under the California Workers’ Compensation Act; (iv) administrative claims for benefits from California’s Employment Development Department; or (v) other claims that cannot be arbitrated as a matter of law, but only when the arbitrability of such claims is not preempted by the FAA. To the extent applicable, this Agreement does not prevent Contractor from filing and pursuing administrative proceedings before the California Civil Rights Department or the United States Equal Employment Opportunity Commission. However, if Contractor pursues a claim following the exhaustion of such administrative remedies, that claim would be subject to this Agreement. This Agreement also does not prevent Contractor from pursuing administrative proceedings before the California Department of Industrial Relations, Labor Commissioner’s Office, under Labor Code Section 98, if applicable. However, if the Company or Contractor seek review of the Labor Commissioner’s order, that claim would be subject to this Agreement.
5. Class and Collective Action Waiver: Company and Contractor agree this Agreement eliminates Contractor’s ability to bring or participate in class or collective actions. No court or arbitrator has the authority to construe this Agreement to allow or permit the consolidation or joinder of other claims or controversies involving any other Contractors in arbitration or permit such claims or controversies to proceed as a class or collective action. By signing this Agreement, Contractor agrees to waive any substantive or procedural rights Contractor may have to sue on a class or collective basis.
6. Individual Arbitration: CALIFORNIA RESIDENTS ONLY: To the extent allowable under applicable law, Contractor agrees to arbitrate any claims, the Company’s defenses to such claims, or any disputes related to California Labor Code violations Contractor allegedly suffered, including claims, defenses, and disputes arising out of or related to California’s Private Attorneys General Act of 2004 (PAGA), on an individual basis. No arbitrator will have the authority under this Agreement to arbitrate claims, defenses or disputes related to Labor Code violations allegedly suffered by non-parties to this Agreement. If a court compels arbitration of individual claims, defenses, or disputes arising out of or related to PAGA, the Company and Contractor agree the court should dismiss any non-individual, representative claims or disputes related to Labor Code violations allegedly suffered by non-parties to this Agreement, to the extent allowable under applicable law. If dismissal of claims related to Labor Code violations allegedly suffered by non-parties to this Agreement is not allowable under applicable law, the Contractor and Company agree to stay such claims pending any arbitration of individual claims, defenses, or disputes arising out of or related to PAGA.
7. Determination of Above Provisions. CALIFORNIA RESIDENTS ONLY: The Company and Contractor agree that a court of competent jurisdiction will be the sole determiner of any disputes regarding whether the FAA applies to this Agreement, whether the Agreement requires individual arbitration of all claims, and whether the Agreement allows for class or collective arbitration. A court of competent jurisdiction will decide all issues about the enforceability of the class or collective waivers herein. The arbitrator has no authority or jurisdiction regarding these issues. If a court enforces the class and collective waiver herein, the Company and Contractor agree the court should also dismiss any class and/or collective claims without prejudice, to the extent allowable under applicable law. If a court determines the prohibition on class or collective actions, or the requirement to arbitrate PAGA claims on an individual basis as set forth above are invalid, the Contractor and Company waive any right to arbitration of class or collective actions, or PAGA actions involving alleged Labor Code violations suffered by non-parties. Instead, the Company and Contractor agree that such claims will proceed in court and not before an arbitrator, but only after the Company and Contractor arbitrate any claims subject to this Agreement.
8. Stay of Non-Arbitrable Claims. The Company and Contractor agree that any non-arbitrable disputes or claims will be severed, separated, and split from arbitrable disputes or claims wherever necessary to ensure enforcement of this Agreement as to any disputes subject to arbitration. The Company and Contractor intend for this Agreement to allow for individual arbitration of disputes and claims to the maximum extent possible. If a party brings claims subject to this Agreement along with non-arbitrable claims, the Company and Contractor agree to stay the non-arbitrable claims pending arbitration of the claims subject to this Agreement.
9. WAIVER OF JURY TRIAL EXCEPT AS STATED HEREIN, THE PARTIES UNDERSTAND AND FULLY AGREE THAT BY ENTERING INTO THIS AGREEMENT TO ARBITRATE, THEY ARE GIVING UP THEIR RIGHT TO HAVE A TRIAL BY JURY AND ARE GIVING UP THEIR NORMAL RIGHTS OF APPEAL FOLLOWING THE RENDERING OF A DECISION EXCEPT AS THE LAW PROVIDES FOR JUDICIAL REVIEW OF ARBITRATION PROCEEDINGS. THE PARTIES ANTICIPATE THAT BY ENTERING INTO THIS AGREEMENT, THEY WILL GAIN THE BENEFITS OF A SPEEDY AND LESS EXPENSIVE DISPUTE RESOLUTION PROCEDURE.
10. Claims Procedure. Arbitration shall be initiated upon the express written notice of either party. The Arbitrator selected will be a retired judge or an otherwise qualified individual, and shall be selected by mutual agreement of the Parties or, if the Parties cannot agree, then by striking from a list of arbitrators supplied by the AAA or any other service provider mutually selected by the Parties. The Arbitrator will be subject to disqualification on the same grounds as would apply to a judge of such court.
11. Venue, Discovery, Motions, and Substantive Law. The Company and Contractor agree to hold the arbitration in Cook County, Illinois. The Parties shall be entitled to conduct discovery sufficient to adequately arbitrate their claims, in accordance with AAA Rules. All applicable rules of pleading, all rules of evidence, all rights to resolution of the dispute by means of motions for summary judgment, judgment on the pleadings, and judgment under applicable rules of civil procedure, including California Code of Civil Procedure Section 631.8, if applicable, will apply and be observed. The Company and Contractor also agree all rights under applicable rules of civil procedure, including California Code of Civil Procedure Section 998 apply, to the extent applicable. The Arbitrator shall apply the substantive law of the State of Illinois or federal law (and the law of remedies, if applicable), as applicable, to the claim(s) and defense(s) asserted. The Arbitrator shall provide a written, reasoned decision explaining his/her findings and conclusions. The Arbitrator may not invoke any basis (including but not limited to, notions of “just cause”) other than such controlling law. The Arbitrator’s decision shall be final and binding upon the Parties. The choice of venue and choice of law provisions set forth herein shall not be applicable to California residents or where otherwise prohibited by applicable law.
12. Arbitration Fees and Costs. Except with respect to California residents or where otherwise required under applicable law, both parties shall be equally responsible for bearing the arbitrator’s fees and expenses. Each party shall pay its own costs and attorneys’ fees, if any. However, if any party prevails on a statutory claim which affords the prevailing party attorneys’ fees and costs, or if there is a written agreement providing for attorneys’ fees and costs, the Arbitrator may award reasonable attorneys’ fees and costs to the prevailing party to the extent allowed by law.
13. Payment. The Company and Contractor agree, time is not of the essence with respect to payment of arbitration provider invoices provided they are paid within a reasonable time. The Company and Contractor stipulate and agree that arbitration invoices may be paid 60 days following the Company’s receipt of an invoice if no due date is stated, and 60 days following the due date stated in the invoice, if a due date is stated.
14. Complete Agreement. The Company and Contractor agree that the terms of this Agreement are the complete and final agreement as to the subject matter addressed herein. No negotiations, oral or written representations, alter this Agreement or vary its terms. The Company and Contractor agree only a signed, written agreement can modify this Agreement.
15. Severability. If a court finds any word, term, phrase, sentence, provision, or portion of this Agreement void or unenforceable, the Company and Contractor agree the court should sever the word, term, phrase, provision, or portion and enforce the remainder of this Agreement to the fullest extent necessary to allow for arbitration of claims, defenses or disputes on an individual basis only.
16. Prior Agreements. If the Company and Contractor have agreed to any prior arbitration agreement, that agreement remains in effect. The Company and Contractor agree this Agreement does not invalidate or supersede any prior arbitration agreement. However, the terms of this Agreement control to the extent there are any conflicting terms in any prior arbitration agreement.
17. Miscellaneous. By executing this Agreement, the Parties represent that they have been given the opportunity to fully review and comprehend the terms of this Agreement. The Company and Contractor agree this Agreement is mutually beneficial. The Company and Contractor also agree such mutuality constitutes sufficient legal consideration to make all obligations agreed to herein enforceable under law.