[brief] Furthermore, [...] underwent multiple defense exams at [...]’s requests, and despite this good-faith cooperation, [...] has persistently delayed its own responses, often supplying only boilerplate answers with improper objections.  Pa0327-Pa0339,  For example, [...] claimed that identifying witnesses present during the incident was “unduly burdensome,” obstructing the [...]’s access to critical information.  Pa0336.  Additionally, despite multiple requests, [...] has not made its corporate representatives or experts available for deposition and has repeatedly hindered Plaintiffs’ attempts to inspect the property.  Pa0285.  At the May 2, 2024, motion hearing, the trial court initially noted that this case had undergone two discovery extensions, totaling over 420 days, with the final extension ending just one day prior, on May 1, 2024.  1T4:18-21.  The court acknowledged the extensive discovery efforts completed to prepare for trial, including depositions of the [...]s and independent medical examinations (IMEs) of [...].  1T4:18-5:3.  Yet, the trial court also referenced that at no point did either Respondent move to stay the proceedings or compel arbitration until this latest motion was filed.  1T4:24-25:5.  The trial court recognized that enforcing the arbitration agreement could prevent the [...]s from accessing crucial discovery materials.  1T7:1-5.  The [...]s argued this restriction would cause them significant prejudice, as it would grant the Defendants access to information unavailable to the [...]s through arbitration.  1T17:15-22.  As to the actual language of the Agreement, [...]s argued that a genuine factual dispute exists regarding whether [...] personally consented to the Arbitration Clause or merely did so on behalf of his son, [...].  1T11:1-5.  They highlighted that it remains unclear whether the agreement [...] signed applied only to his son as the “jumper,” with [...] acting only as a supervisor, or whether it was also intended to cover [...] as a “jumper” himself.  1T11:6-11.  If the latter is true, [...] would have been required to sign two separate agreements - one for his son and one for himself.  Ibid.  Crucially, [...]’s counsel conceded that they were uncertain of their own policy on whether an adult who intends to participate alongside a minor must sign separate arbitration agreements for themselves and the minor.  1T21:8-14.  The [...]s also noted that [...] had very limited time to review the Agreement before signing, approximately one to two minutes, while a line formed behind him.  1T11:14-21.  The [...]s further highlighted that [...] felt pressured to sign the document and was unaware of what he was actually agreeing to at the time of the incident.  1T13:18-14:4.  Despite the lack of clarity on [...]’s policy regarding separate agreements for a parent and minor, the trial court mistakenly concluded it was “undisputed” that [...] signed the Agreement on behalf of both himself and his son.  1T27:9-15.  The court neglected to address other key issues, including concerns about [...]’s unsafe conditions, the parties’ engagement in civil discovery, and the need for a factual hearing on the arbitration agreement.  1T27:17-29:10.  Given these unresolved disputes, it was improper for the trial court to compel arbitration.  The presence of significant factual issues requires further examination by a factfinder, not dismissal through motion practice, making it clear that the Respondents’ motion is unfounded and should not have been granted under New Jersey law.  LEGAL ARGUMENT I.