Gomez v. Hiregenics Inc., et al

1 CASE NO. 2:25-CV-03569-TLN-CKD
JOINT STIP TO ARBITRATE; ORDER
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Guillermo A. Escobedo (SBN 206198)
gescobedo@constangy.com
Komal Jain (SBN 309827)
kjain@constangy.com
Anissa Elhaiesahar (SBN 354942)
aelhaiesahar@constangy.com
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)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
BRENDA GOMEZ, an individual,
Plaintiff,
vs.
HIREGENICS INC., a Delaware Corporation;
ABBOTT LABORTORIES, an Illinois
corporation, and DOES 1 through 100, inclusive,
Defendants.
Case No.: 	2:25-CV-03569-TLN-CKD
JOINT STIPULATION TO SUBMIT
PLAINTIFF’S CLAIMS TO ARBITRATION;
AND ORDER
Complaint filed: 	November 5, 2025
Trial Date: 	N/A
Case 2:25-cv-03569-TLN-CKD Document 17 Filed 01/07/26 Page 1 of 6

1 CASE NO. 2:25-CV-03569-TLN-CKD
JOINT STIP TO ARBITRATE; ORDER
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Onyebuchi Okeke (SBN 338730)
ookeke@lfecr.com
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)
jcurley@seyfarth.com
Steven Wong (SBN 293343)
stewong@seyfarth.com
SEYFARTH SHAW LLP
560 Mission Street, Suite 3100
San Francisco, California 94105
Telephone: 	(415) 397-2823
Attorneys for Defendant
ABBOTT LABORATORIES
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1 CASE NO. 2:25-CV-03569-TLN-CKD
JOINT STIP TO ARBITRATE; ORDER
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Plaintiff BRENDA GOMEZ, (“Plaintiff”) on the one hand and Defendant HIREGENICS INC.
(“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.
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”);
WHEREAS, on or about December 9, 2025, Abbott filed an answer in state court;
WHEREAS, on or about December 10, 2025, HireGenics filed an answer in state court;
WHEREAS, on or about December 11, 2025, Abbot filed a Notice of Removal to the Eastern
District of California;
WHEREAS, on or about December 11, 2025, Plaintiff’s counsel informed counsel for Abbot that
Plaintiff is agreeable to stipulate to arbitration;
WHEREAS, on December 12, 2025, HireGenics filed a Consent to Removal and Joinder in Notice
of Removal of Action by co-defendant Abbott;
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;
WHEREAS, this Stipulation is not made to cause any unwarranted or unnecessary delay to these
proceedings;
WHEREAS, none of the Parties will be prejudiced by the Court granting this Stipulation;
NOW THEREFORE, the Parties, through their respective counsel, hereby agree and stipulate to
the following:
1. 	Plaintiff executed an arbitration agreement on October 21, 2022 with HireGenics, which is
attached hereto as Exhibit A;
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JOINT STIP TO ARBITRATE; ORDER
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2. 	The Parties agree that the claims alleged in the Complaint against Defendants are subject
binding arbitration with a mutually agreeable arbitrator, using the JAMS Employment
Arbitration Rules & Procedures;
3. 	Defendant Abbott is a third-party beneficiary to the arbitration agreement attached as Exhibit
A;
4. 	The Action present in the Federal Court shall be stayed;
5. 	The Parties agree that the arbitration proceeding shall fully comply with the requirements of
Armendariz v. Foundation Health (2000) 24 Cal.4th 83, in that the arbitration shall: (a) provide
a neutral arbitrator; (b) allow sufficient discovery; (c) provide all types of relief available to
Plaintiff that otherwise would be available in court; (d) provide a written arbitration award
given by the arbitrator; and (e) require Defendants to pay all arbitrator’s fees and all costs
unique to arbitration to the full extent of its legal duty to do so, pursuant to Armendariz, supra,
24 Cal.4th 102, 108-109;
6. 	This entirety of Plaintiff’s claims against Defendants will proceed in its entirety in arbitration,
and the Parties will be permitted to engage in discovery as agreed to by the Parties, and/or as
permitted by the arbitrator;
7. 	This Court shall retain jurisdiction of this matter to enforce the Stipulation to Arbitrate this
matter, to enforce any arbitration award, and to perform any other roles as permitted by
applicable law, and;
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
IT IS SO STIPULATED.
DATED: January 5, 2026 	CONSTANGY, BROOKS,
SMITH & PROPHETE, LLP
By: 	s/ Komal Jain
Guillermo A. Escobedo
Komal Jain
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3 CASE NO. 2:25-CV-03569-TLN-CKD
JOINT STIP TO ARBITRATE; ORDER
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Anissa Elhaiesahar
Attorneys for Defendant
HIREGENICS INC.
DATED: 12/31/2025 	LAWYERS 	FOR 	EMPLOYEE 	AND
CONSUMER RIGHTS
By: 	s/ *Onyebuchi Okeke
Onyebuchi Okeke
Attorneys for Plaintiff
BRENDA GOMEZ
DATED: January 5, 2026 	SEYFARTH SHAW LLP
By: 	s/ *Justin T. Curley
Justin T. Curley
Steven Wong
Attorneys for Defendant
ABBOTT LABORATORIES
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JOINT STIP TO ARBITRATE; ORDER
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ORDER
Based on the foregoing Joint Stipulation of the Parties, and the subject arbitration agreements, and
good cause having been shown, IT IS HEREBY ORDERED:
1. 	All of Plaintiff’s claims against all of the Defendants asserted in Plaintiff’s
Complaint be submitted to binding arbitration;
2. 	The entirety of this Action shall be stayed pending the completion of the arbitration
proceedings; and
3. 	This Action, and all claims asserted therein, shall be stayed pending the results of
the Parties’ arbitration, as required by the Federal Arbitration Act, 9 U.S.C. § 3.
IT IS SO ORDERED.
Date: January 7, 2026____________________________
Troy L. Nunley
Chief United States District Judge
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