Brenda Gomez v. Hiregenics Inc.

1 [email protected] Komal Jain (SBN 309827) [email protected] Anissa Elhaiesahar (SBN 354942) [email protected] CONSTANGY, BROOKS, SMITH & PROPHETE, LLP 550 West C Street, Suite 1400 San Diego, CA 92101 Telephone: (619) 605-6171 Attorneys for Defendant HIREGENICS INC. (Additional counsel listed on next page) 12 UNITED STATES DISTRICT COURT 13 EASTERN DISTRICT OF CALIFORNIA BRENDA GOMEZ, an individual, Case No.: 2:25-CV-03569-TLN-CKD 15 Plaintiff, JOINT STIPULATION TO SUBMIT 16 PLAINTIFF’S CLAIMS TO ARBITRATION; vs. AND ORDER HIREGENICS INC., a Delaware Corporation; Complaint filed: November 5, 2025 ABBOTT LABORTORIES, an Illinois Trial Date: N/A corporation, and DOES 1 through 100, inclusive, Defendants.

1 [email protected] LAWYERS FOR EMPLOYEE AND CONSUMER RIGHTS 3500 West Olive Avenue, Third Floor Burbank, CA 91505 Telephone: (323) 375-5101 Attorneys for Plaintiff BRENDA GOMEZ Justin T. Curley (SBN 233287) [email protected] Steven Wong (SBN 293343) [email protected] SEYFARTH SHAW LLP Mission Street, Suite 3100 San Francisco, California 94105 Telephone: (415) 397-2823 Attorneys for Defendant ABBOTT LABORATORIES (“HIREGENICS”) and Defendant ABBOTT LABORATORIES (“ABBOTT”) (HIREGENICS and ABBOTT collectively, “Defendants”) (Plaintiff and Defendants collectively, the “Parties”), by and through their respective counsel, hereby submit the following Joint Stipulation and Proposed Order to stay this matter and proceed in arbitration.

6 WHEREAS, Plaintiff filed her Complaint on November 5, 2025, asserting various employment- related claims against Defendants for alleged violations of the California Labor Code, the Fair Employment and Housing Act (“FEHA”) and the California Business and Professions Code §§ 17200, et seq. (the “Action”); 10 WHEREAS, on or about December 9, 2025, Abbott filed an answer in state court; 11 WHEREAS, on or about December 10, 2025, HireGenics filed an answer in state court; 12 WHEREAS, on or about December 11, 2025, Abbot filed a Notice of Removal to the Eastern District of California; 14 WHEREAS, on or about December 11, 2025, Plaintiff’s counsel informed counsel for Abbot that Plaintiff is agreeable to stipulate to arbitration; 16 WHEREAS, on December 12, 2025, HireGenics filed a Consent to Removal and Joinder in Notice of Removal of Action by co-defendant Abbott; 18 WHEREAS, in the interests of judicial economy along with the mutual desire to preserve the Court’s resources, the Parties stipulate to proceed in arbitration; 20 WHEREAS, this Stipulation is not made to cause any unwarranted or unnecessary delay to these proceedings; 22 WHEREAS, none of the Parties will be prejudiced by the Court granting this Stipulation; 23 NOW THEREFORE, the Parties, through their respective counsel, hereby agree and stipulate to the following: 25 1. Plaintiff executed an arbitration agreement on October 21, 2022 with HireGenics, which is 26 attached hereto as Exhibit A; 2 binding arbitration with a mutually agreeable arbitrator, using the JAMS Employment 3 Arbitration Rules & Procedures; 4 3. Defendant Abbott is a third-party beneficiary to the arbitration agreement attached as Exhibit 5 A; 6 4. The Action present in the Federal Court shall be stayed; 7 5. The Parties agree that the arbitration proceeding shall fully comply with the requirements of 8 Armendariz v. Foundation Health (2000) 24 Cal.4th 83, in that the arbitration shall: (a) provide 9 a neutral arbitrator; (b) allow sufficient discovery; (c) provide all types of relief available to 10 Plaintiff that otherwise would be available in court; (d) provide a written arbitration award 11 given by the arbitrator; and (e) require Defendants to pay all arbitrator’s fees and all costs 12 unique to arbitration to the full extent of its legal duty to do so, pursuant to Armendariz, supra, 13 24 Cal.4th 102, 108-109; 14 6. This entirety of Plaintiff’s claims against Defendants will proceed in its entirety in arbitration, 15 and the Parties will be permitted to engage in discovery as agreed to by the Parties, and/or as 16 permitted by the arbitrator; 17 7. This Court shall retain jurisdiction of this matter to enforce the Stipulation to Arbitrate this 18 matter, to enforce any arbitration award, and to perform any other roles as permitted by 19 applicable law, and; 20 THEREFORE, the Parties respectfully request that the Court, under California Code of Civil Procedure § 1280, et seq., order the Action to be immediately stayed pending submission to binding arbitration as consistent with the provisions set forth in this Stipulation 24 IT IS SO STIPULATED.

25 DATED: January 5, 2026 CONSTANGY, BROOKS, SMITH & PROPHETE, LLP By: s/ Komal Jain 28 Guillermo A. Escobedo Attorneys for Defendant 3 HIREGENICS INC.

6 DATED: 12/31/2025 LAWYERS FOR EMPLOYEE AND CONSUMER RIGHTS By: s/ *Onyebuchi Okeke Onyebuchi Okeke Attorneys for Plaintiff 11 BRENDA GOMEZ

DATED: January 5, 2026 SEYFARTH SHAW LLP

15 By: s/ *Justin T. Curley Justin T. Curley 16 Steven Wong 17 Attorneys for Defendant ABBOTT LABORATORIES

> ORDER 3 Based on the foregoing Joint Stipulation of the Parties, and the subject arbitration agreements, and good cause having been shown, IT IS HEREBY ORDERED: 5 1. All of Plaintiff's claims against all of the Defendants asserted in □□□□□□□□□□□ 6 Complaint be submitted to binding arbitration; 4 2. The entirety of this Action shall be stayed pending the completion of the arbitration 8 proceedings; and 9 3. This Action, and all claims asserted therein, shall be stayed pending the results of 10 the Parties’ arbitration, as required by the Federal Arbitration Act, 9 U.S.C. § 3.

12 IT IS SO ORDERED.

14 Date: January 7, 2026 Troy L. Nun 15 Chief United States District Judge □ _ CASE NO. 2:25-CV-03569-TLN-CKD