On August 2, 2017, Plaintiff Matthew Easterbrook (“Plaintiff”) filed a complaint against Inter-Con Security Systems, Inc. (“Inter-Con”), California Department of Transportation (“Cal-Trans”), Vince Zorn (“Zorn”), Buddy Cruz (“Cruz”), and Leonard Phillips (“Phillips”). The complaint alleges eight causes of action for violations of the Labor Code, FEHA, and Business and Professions Codes section 17200. All causes of action are alleged against all Defendants.

Defendant Inter-Con moves to have Plaintiff’s claims against it sent to binding arbitration pursuant to an arbitration agreement executed by Plaintiff, (“Agreement”) and to stay this action pending the arbitration (“Motion”). Plaintiff opposes the Motion (“Opposition”).1

Plaintiff alleges that he worked as a security guard for Inter-Con on properties owned and operated by Defendant Cal-Trans from approximately July 2012 through his termination, on or about September 2015. Plaintiff was also instructed to engage in mail delivery du