Joint Motion to Stay These Proceedings Pending Arbitration by Rocket Mortgage, LLC. (Thomson, Jeffrey)

Document #6 Filed 06/01/2026 · 6 pages · District Court, E.D. Michigan · View original PDF

1Plaintiff filed this action on March 27, 2026.

2Rocket Mortgage’s response to the complaint is currently due June 1, 2026. In pre-filing meet and confer communications about that response, Rocket Mortgage advised Plaintiff’s counsel that Rocket Mortgage intended to file a motion to compel arbitration of Plaintiff’s claims based upon an agreement to arbitrate.

3As a result of discussion between them about the arbitration agreement, the parties have agreed to resolve Plaintiff’s claims through arbitration.

4Under these circumstances, 9 U.S.C. § 3 provides that the district court shall stay the action “until [the] arbitration has been had in accordance with the terms of the agreement.”

5Accordingly, the parties respectfully request that the Court stay all proceedings in this matter pending the completion of the arbitration proceedings.

6Rocket Mortgage reserves the right to file a motion to dismiss this action in the future if the stay sought herein is not granted, or if the stay is granted and then subsequently lifted such that the case is no longer stayed. Respectfully submitted, /s/ Mohammed O. Badwan Mohammed O. Badwan, Esq. Sulaiman Law Group, Ltd. 2500 South Highland Avenue Suite 200 Lombard, IL 60148 Telephone: (630) 575-8180 [email protected] Counsel for Plaintiff

Respectfully submitted, /s/ Jeffrey M. Thomson Jeffrey M. Thomson (P72202) MORGANROTH & MORGANROTH PLLC 344 North Old Woodard Avenue, Suite Birmingham, MI 48009 Tel.: +1 248 864 4000 Fax: +1 248 864 4001 [email protected] Counsel for Rocket Mortgage, LLC IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN

MARSHA A. KERR, individually, and on behalf of all others similarly situated,

Plaintiff, v.

ROCKET MORTGAGE, LLC

Defendant.

Case No. 4:26-cv-11028-FKB-CI Hon. F. Kay Behm U.S. District Judge Hon. Curtis Ivy, Jr. U.S. Magistrate Judge BRIEF IN SUPPORT OF JOINT MOTION TO STAY THESE PROCEEDINGS PENDING ARBITRATION i STATEMENT OF ISSUE PRESENTED

Whether the Court should enter an order staying this matter pending completion of arbitration proceedings where the parties have entered into an arbitration agreement that delegates questions of arbitrability to the arbitrator and the parties have agreed to resolve the claims asserted by Plaintiff through arbitration.

ii STATEMENT OF CONTROLLING AUTHORITY

9 U.S.C. § 3 (“If any suit or proceeding be brought in any of the courts of the United States upon any issue referable to arbitration under an agreement in writing for such arbitration, the court in which such suit is pending, upon being satisfied that the issue involved in such suit or proceeding is referable to arbitration under such an agreement, shall on application of one of the parties stay the trial of the action until such arbitration has been had in accordance with the terms of the agreement . . .”.).

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Public U.S. federal court record (district court docket 73105055, document 6). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.