[brief] In or around November of 2024, Appellants were able to gain access to Respondent’s former [...] email account.  A member of [...]’s IT Department was able to reset the email account’s password and provided it to counsel.  Upon receiving the new password, [...], Esq.  (“Polychronis”), an attorney at [...], counsel for Appellants, was able to gain access to [...]’s former [...] email account and review her sent messages.  Within the sent messages Polychronis located the November 2019 Email from [...] to [...], attaching a zip folder containing twenty-three (23) documents, one of which entitled “Employment contracts- signed”.  As stated above, this document included seven (7) executed employment agreements, one of which was Operative Agreement.  Four of these agreements were signed in 2019 and contained virtually identical arbitration provisions found in the Operative Agreement.  1T at 20:12-25:6.  Some of these agreements were signed before the date [...] signed her agreement and some were dated after.  108a-166a.  Unlike the Incomplete Agreement, the Operative Agreement does not contain discrepancies.  [...] initialed the bottom of each page, the spacing is consistent throughout the document, the pages are correctly numbered, and there are no blank pages.  Most significantly, the Operative Agreement signature page (page 9) is identical to the signature page found in the Incomplete Agreement.  However, pages 8 and 9 of the Operative Agreement are cohesive.  The last paragraph at the bottom of page 8, which carries over to page 9, states:  Employee represents and warrants that he or she is not a party to or otherwise subject to or bound by the terms of any contract, agreement or understanding that in any manner would limit or otherwise affect Employee’s ability to perform the duties and obligations of this At-Will Employment Agreement.  Employee [page 9] agrees to indemnify and hold harmless [...] for any actions[…]  [165a-166a].  On November 22, 2023, Appellants wrote to [...]’s counsel to inform him that the Operative Agreement was located.  A copy of the November 2019 Email, a screenshot of its attachments and the Operative Agreement were attached.  The letter also offered to provide [...] and her counsel the November 2019 email and its attachments in native format for their inspection.  307a-308a.  [...], however, never requested it.  Despite this fully integrated agreement, that was sent by [...] herself knowing it was being produced to, and would be relied upon by, the [...], along with other agreements with the same arbitration clause and that were either signed by [...] on behalf of [...] or as a witness, Respondent maintained her position that she was not bound by any arbitration provision.  167a-168a.  On December 21, 2023, Appellants filed a letter with the trial Court, attaching the November 2019 Email, a screenshot of its attachments, and the Operative Agreement, and advised [...] that Appellants located the Operative Agreement and suggested that the plenary hearing was unnecessary.  96a-97a.  Thereafter, Appellants sought to depose [...] but her counsel refused to produce her for her deposition, forcing Appellants to file a motion to compel on the limited topic of whether there is an enforceable agreement to arbitrate [...]’s claims.