[brief] On August 22, 2023, Plaintiff [...] filed a Verified Complaint (Da3-23) and proposed Order to Show Cause with Temporary Restraints (Da24-28) against [...] (“[...]”), [...] (“[...]”) (collectively, “the Companies”), and [...] (collectively, “Defendants”) in the Superior Court of New Jersey, Bergen County, Chancery Division, bearing docket number [...] (“Chancery Action”).  The Chancery Complaint sought specific performance of a written agreement to transfer title from [...] to Plaintiff for the building and property located at [...] (“the Property”) as the remedy for her breach of contract claims asserted against Defendants.  (Da3).  On August 22, 2023, [...], [...], and the [...] by and through its Executors [...] and [...] a/k/a [...], filed a Verified Complaint against [...]-Elian, [...], [...], and [...], in the Superior Court of New Jersey, Bergen County, Law Division, bearing docket number [...] (“Law Division Action”).  (Da75-103).  The Law Division Action alleges claims of breach of contract, breach of covenant of good faith and fair dealing, breach of fiduciary duty, breach of statutory duty of loyalty and care, negligence, gross negligence, fraud, unjust enrichment, conversion, violation of Civil Racketeering Influenced and Corrupt Organizations Act, and civil conspiracy that all arise out of Plaintiff Miqueo’s role as Manager of the Property.  (Da75-103).  On August 28, 2023, the Chancery court entered an Order to Show Cause with Temporary Restraints, enjoining Defendants from engaging in any acts outside of the ordinary course of operation and business which could affect the ownership or value of the building and property located at the Property.  (Da104-108).  On September 8, 2023, Defendants filed an expedited Motion on short notice to dissolve or modify the restraints, as well as an Order to Show Cause to disqualify Plaintiff’s counsel.  (Da110-12; 1T41:19-23; 1T42:24-25; 1T45:9).  Defendants ultimately withdrew their Motion to disqualify Plaintiff’s counsel in the chancery matter, and on October 5, 2023, new counsel substituted in for Plaintiff.  (Da218).  On October 19, 2023, Defendants filed their Answer to the Chancery Complaint, with Counterclaims.  (Da220-48).  On October 23, 2023, the Chancery court entered an Order for the parties to attend mediation and scheduled trial for August 6, 2024.  (Da219).  Thereafter, the parties mediated in December 2023 with the Honorable [...], J.S.C. (Ret.), but mediation was unsuccessful.  (T45:5-10; Da263-64; 1T45:5-10).  In January 2024, Plaintiff filed her Answer to Defendants’ Counterclaims.  (Da265-74; 1T45:11-12).  On January 19, 2024, Plaintiff filed a Motion to Consolidate the Chancery Action with the Law Division Action, which was ultimately denied on March 8, 2024.  (Da275-77, Da299-300; 1T45:13).  On March 8, 2024, the parties began to engage in discovery in the Chancery Action.  (1T12:17-18).  On April 10, 2024, Plaintiff filed a Motion to Compel Arbitration in the Law Division Action (Da301-03) however that application was eventually withdrawn, as the parties agreed to mediate, which was memorialized in Consent Orders dated May 28, 2024, and July 30, 2024.  (Da332-33; 1T43:11-13).  On May 17, 2024, Plaintiff filed the Motion to Compel Arbitration in the Chancery Action that is the subject of this appeal.