JOINT STIPULATION AND [PROPOSED] ORDER FOR BINDING ARBITRATION AND TO STAY ACTION PENDING ARBITRATION

JOHN A. MENDEZ, District Judge.

Plaintiff Donald Higgins ("Plaintiff") and Defendant Bill Me Later, Inc. ("Defendant") (collectively, "Parties"), by and through their undersigned counsel of record in this matter, stipulate and agree as follows:

WHEREAS, Plaintiff filed this action on February 1, 2018;

WHEREAS, Parties to this dispute are signatories to a contract mandating all disputes be resolved through arbitration with the American Arbitration Association, attached as Exhibit A.

IT IS HEREBY STIPULATED by and between Plaintiff, on the one hand, and Defendant, on the other hand, that:

1. This matter be stayed in its entirety pursuant to 9 U.S.C. § 3.

2. This action must be submitted to arbitration pursuant to the terms set forth in the arbitration agreement agreed to by both Plaintiff and Defendant.

[PROPOSED]ORDER

The Court has reviewed the Joint Stipulation to Stay Action Pending Arbitration. Good cause appearing therefor, the Court orders as follows:

1. This matter is hereby stayed in its entirety pursuant to 9 U.S.C. § 3; and

2. This action shall be submitted to arbitration pursuant to the terms set forth in the arbitration agreement agreed to by both Plaintiff and Defendant.

3. The parties shall file a joint status report upon completion of the arbitration or not later than six months from the date of this order whichever comes first.

IT IS SO ORDERED.

EXHIBIT A