Turner v. J.P. Morgan Chase Bank
Filing
14
ORDER GRANTING 13 Stipulation to Arbitrate and to Stay and Requiring Joint Status Reports. Signed by Judge Jeffrey S. White on October 2, 2012. (jswlc3, COURT STAFF) (Filed on 10/2/2012)
Case3:12-cv-04161-JSW Document13 Filed10/01/12 Page1 of 14
M ILLER L AW G ROUP
A P RO F E SSIO NAL C O RPO RATIO N
C ALIF O RNIA
1 Pamela Pitt (SBN 156395)
pittlawoffice@gmail.com
2 Maria Bourn (SBN 269322)
mariabourn@gmail.com
3 LAW OFFICE OF PAMELA PITT
4 22 Battery Street, Suite 1000
San Francisco, CA 94111
5 Tel: 415-291-0251
Fax: 415-291-9252
6
Attorneys for Plaintiff
7 TWIALLA TURNER
8 Michele Ballard Miller (SBN 104198)
mbm@millerlawgroup.com
9
Jennifer Cotner (SBN 255785)
jrc@millerlawgroup.com
10
MILLER LAW GROUP
11 A Professional Corporation
111 Sutter Street, Suite 700
12 San Francisco, CA 94104
Tel. (415) 464-4300
13 Fax (415) 464-4336
14 Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.
15
16
17
IN THE UNITED STATES DISTRICT COURT
18
NORTHERN DISTRICT OF CALIFORNIA
19
20
TWIALLA TURNER,
21
Case No.: CV 12 4161 JSW
Plaintiff,
22 v.
23
J. P. MORGAN CHASE BANK, and DOES 1
24 through 20, DEFENDANTS,
STIPULATION AND [PROPOSED] ORDER
TO ARBITRATE AND STAY ACTION
AND REQUIRING JOINT STATUS
REPORTS
Complaint filed: August 8, 2012
25
26
Defendants.
27
28
STIPULATION AND [PROPOSED] ORDER TO ARBITRATE AND STAY ACTION
Case No.: CV 12 4161 JSW
Case3:12-cv-04161-JSW Document13 Filed10/01/12 Page2 of 14
1
Plaintiff TWIALLA TURNER (“Plaintiff”) and Defendant JPMORGAN CHASE
2 BANK, N.A. (incorrectly named as J. P. Morgan Chase Bank) (“Defendant”), through their
3 respective attorneys, hereby stipulate as follows:
4
5
WHEREAS, Plaintiff signed an offer letter on or about August 17, 2010
6 requiring that she agree to resolve all employment-related disputes with her employer that
7 cannot be resolved internally to binding arbitration, as set forth in the Binding Arbitration
8 Agreement (the “Agreement”) with Defendant. True and correct copies of the offer letter
9 and Binding Arbitration Agreement are attached as Exhibit A;
10
11
WHEREAS, the Agreement indicates that all “covered claims” “shall be
M ILLER L AW G ROUP
A P RO F E SSIO NAL C O RPO RATIO N
C ALIF O RNIA
12 submitted to and resolved by final and binding arbitration in accordance with this
13 Agreement.” (Agreement, ¶ 1) “‘Covered Claims’ include all legally protected employment14 related claims, excluding those set forth below in Paragraph 3 and 4 of this agreement [not
15 applicable to this case], that I have or in the future may have against JPMorgan Chase or its
16 officers, directors, shareholders, employees or agents which arise out of or relate to my
17 employment or separation from employment with JPMorgan Chase and all legally protected
18 employment-related claims that JPMorgan Chase has or in the future may have against me,
19 including, but not limited to, claims of employment discrimination or harassment if protected
20 by applicable federal, state or local law, and retaliation for raising discrimination or
21 harassment claims, failure to pay wages, bonuses or other compensation, tortious acts,
22 wrongful, retaliatory and/or constructive discharge, breach of an express or implied contract,
23 promissory estoppel, unjust enrichment, and violations of any other common law, federal,
24 state, or local statute, ordinance, regulation or public policy….” (Agreement, ¶ 2) In Ms.
25 Turner’s offer letter, she signed an affirmation as follows: “I understand my employment is
26 subject to my and JPMorgan Chase’s agreement to submit employment-related disputes
27 that cannot be resolved internally to binding arbitration, as set forth in the Binding
28 Arbitration
Agreement
1
STIPULATION AND [PROPOSED] ORDER TO ARBITRATE AND STAY ACTION
Case No.: CV 12 4161 JSW
Case3:12-cv-04161-JSW Document13 Filed10/01/12 Page3 of 14
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