[brief] Plaintiff Cannot Demonstrate That The Terms Of The MAA Are Unconscionable.  Plaintiff’s contention that the adhesive nature of the MAA renders it unconscionable must also be rejected.  (Pb33-Pb34).  As New Jersey courts have repeatedly held, that a contract is one of adhesion does not mean that the agreement is automatically unenforceable; rather, “[t]he determination that a contract is one of adhesion . . . ‘is the beginning, not the end, of the inquiry’ into whether a contract, or any specific term therein, should be deemed unenforceable based on policy considerations. ”  Muhammad v. County Bank of Rehobeth Beach, 189 N.J. 1, 15 (2006), cert. denied, 549 U.S. 1338 (2007) (quoting Rudbart v. Water Supply Com’m., 127 N.J. 344, 354, cert. denied, 506 U.S. 871 (1992)).  A plaintiff attempting to establish unconscionability of an arbitration provision in the context of an employment agreement cannot rely solely on the fact that the agreement, to some degree, is a contract of adhesion because there is no public policy reason not to enforce a properly drafted arbitration agreement in an employment contract.  Garfinkel, 168 N.J. at 135.  Given the fact that our courts view arbitration as a “favored . . . means of resolving disputes,” Martindale, 173 N.J. at 84, mere inequality in bargaining power is not sufficient to render a facially valid arbitration agreement unenforceable.  Young, 297 N.J. Super. at 621.  In fact, “[v]irtually every court that has considered the adhesive effect of arbitration provisions in employment applications or employment agreements has upheld the arbitration provision contained therein despite potentially unequal bargaining power between employer and employee. ”  Martindale, 173 N.J. at 90-91.  Likewise, to avoid an arbitration clause, a plaintiff must show “circumstances substantially more egregious than the ordinary economic pressure faced by every employee who needs the job. ”  Young, 297 N.J. Super. at 621.  Here, Plaintiff offers nothing to support her unconscionability argument other than “[i]f [she] wanted to work, she was required to agree to arbitrate her claims of discrimination” and thus she “was left with simply no choice but to ‘accept’ the terms of the [MAA].” (Pb33).  This reason, standing alone, is wholly insufficient to support a challenge to the validity of the MAA as a matter of established law.  Martindale, 173 N.J. at 90.  Even if Plaintiff failed to carefully read what she was signing, her action or lack thereof does not now render the MAA an unenforceable contract of adhesion.  Jones v. Dish Network LLC, No. A-2653-12T4, 2013 WL 6169215, at *4 (App. Div. Nov. 26, 2013) (“Plaintiff's contention that, on her first day of employment she was handed a stack of documents and told to sign them, without further explanation of their contents, falls far short of alleging either fraud or an unenforceable adhesion contract. ”).  Because Plaintiff does not and cannot --- 4  Plaintiff’s argument in her brief that “she was instructed to login on her cell phone so she could complete [the onboarding forms] immediately while she was in the waiting room for a doctor’s appointment” lacks support in the record, and, in fact, is contradicted by Plaintiff’s Certification which provides that Plaintiff, herself, made the decision to complete the onboarding forms on her cell phone while waiting for her pre-hiring health examination because [...] urged her to complete onboarding “as soon as possible. ” (Pa137 at ¶¶ 10-12).  demonstrate that the MAA is manifestly unfair or oppressive, the MAA must be enforced as written.  POINT II