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Griffin v. United Health Care Services

10/31/2005

nal, exclusive and required forum for the resolution of all employment related disputes which are based on a legal claim. I agree to submit all employment related disputes based on a legal claim to arbitration under UHC's policy." Griffin's signature appears above the signature line.


The bottom of page two of the Code of Conduct Acknowledgement has lines for the date, location, employee signature, and printed employee name.


Griffin was terminated on March 18, 2004.


2. Juanita McVey applied to work at United Behavioral Health on June 26, 2000. She signed the acknowledgment on the application form (hereafter Employment Application) that states, inter alia: "I understand that UnitedHealth Group has adopted alternative dispute resolution procedures, including an Employment Arbitration Policy, to resolve any dispute which may arise related to my employment or termination of employment. I understand that arbitration is the exclusive forum for the resolution of employment related disputes which are based on a legal claim and that arbitration decisions are final and binding upon both myself and UnitedHealth Group. I agree to comply with UnitedHealth Group's Internal Dispute Resolution policy and UnitedHealth Group's Employment Arbitration Policy in any covered employment dispute with UnitedHealth Group."


McVey signed the Code of Conduct Acknowledgement on July 10, 2000. She was employed when this action commenced.


3. Evelyn Woods signed a document entitled "U.S. Behavioral Health Principles of Employment" on June 12, 1995. It states: "As you consider our offer to become an employee of U.S. Behavioral Health, there are certain matters which we want to clarify. First, you must observe the policies which we publish from time to time for employees. . . . These expectations are included in the U.S. Behavioral Health Dispute Resolution Procedure, and U.S. Behavioral Health Employment Arbitration Policy, and are contained in the Employee Handbook. Copies of these policies are enclosed for your reference. By signing this document you agree to comply with all the Policies and Procedures that are described therein. [ ] [ ] Fourth, you agree to follow our dispute resolution/arbitration procedures for employment disputes [including all claims arising under federal, state, and local statutes concerning employment discrimination. If internal dispute procedures do not resolve disputes], you and we agree . . . to submit the dispute . . . to binding arbitration before the arbitration facilities of the American Arbitration Association (AAA) in accordance with the Arbitration rules of that body then in effect and as supplemented by the U.S. Behavioral Health Employment Arbitration Policy. . . . Again, it is your responsibility to read and understand the dispute resolution/arbitration procedures. If you have any questions, now or in the future, please ask."


Woods signed the Code of Conduct Acknowledgement on March 13, 1996. She was terminated on May 11, 2004.


4. Fikirte Samson signed the Employment Application on May 22, 1997. The letter offering her a job specifies that United HealthCare's internal dispute and Employment Arbitration Policy, which accompanied the offer letter, is a condition of employment.


Samson signed the Code of Conduct Acknowledgement on June 16, 1997. She was terminated on April 2, 2004.


5. RoseMary Rayson signed the Employment Application on October 28, 1995. On November 15, 1995, she signed the same "Principles of Employment" that Woods had executed. On March 19, 1996, she signed the Code of Conduct Acknowledgement. She was employed when this action commenced.


6. Mary Perryman signed the

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