Full Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3. SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2982-24 NOEL LOPEZ, on behalf of himself and those similarly situated, Plaintiff-Appellant, v. CARZ4US LLC, CREDIT ACCEPTANCE CORPORATION and WYNN'S EXTENDED CARE, INC., Defendants-Respondents. _______________________________ Argued October 6, 2026 – Decided November 5, 2026 Before Judges Gummer, Paganelli, and DeAngelis. On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Docket No. L-6684-24. Yongmoon Kim argued the cause for appellant (Kim Law Firm LLC, attorneys; Yongmoon Kim and Nick Gagua, on the briefs). Fruqan Mouzon argued the cause for respondent Carz4Us, LLC (Fox Rothschild LLP, attorneys; Timothy J. Broking, of counsel and on the brief; Francis G. Tiongson, on the brief). Ryan L. DiClemente (Husch Blackwell LLP) argued the cause for respondent Credit Acceptance Corporation (Ryan L. DiClemente and Kellie A. Lavery (Husch Blackwell LLP), attorneys; Ryan L. DiClemente and Kellie A. Lavery, of counsel and on the brief). Kevin M. McKeon argued the cause for respondent Wynn's Extended Care, Inc. (Marshall Dennehey, PC, attorneys; Kevin M. McKeon, on the brief). PER CURIAM In this case about a used-car purchase, plaintiff Noel Lopez appeals from orders granting defendants' motions to compel arbitration and dismiss the complaint. Based on our de novo review, we affirm the aspects of the orders compelling arbitration. Because the trial court should have stayed the case pending arbitration instead of dismissing it, we vacate the aspects of the orders dismissing the complaint and remand the case for entry of an order staying the case in the Law Division pending arbitration. I. On October 12, 2023, plaintiff visited the dealership of defendant Carz4Us, LLC (Carz). According to plaintiff, his daughter accompanied him and acted as his translator because Spanish is his first language. Plaintiff A-2982-24 2 ultimately purchased a 2013 Honda Odyssey from Carz and executed several documents he "presumed to be sales documents" in completing the transaction. Plaintiff and Carz executed a "Used Motor Vehicle Retail Order" (retail order). The retail order described the transaction as a "[f]inance [p]urchase" and stated the vehicle was being sold "as is." The second page of the retail order contained an arbitration clause, which provided: AGREEMENT TO ARBITRATE ALL CLAIMS. READ THE FOLLOWING ARBITRATION PROVISION CAREFULLY, IT LIMITS YOUR RIGHTS, AND WAIVES THE RIGHT TO MAINTAIN A COURT ACTION, OR TO PURSUE A CLASS ACTION IN COURT AND IN ARBITRATION. The parties to this agreement agree to arbitrate all claims, disputes, or controversies . . . that may arise out of or relating to this agreement and the sale or lease identified in this agreement. By agreeing to arbitrate, the parties understand and agree that they are giving up their rights to use other available resolution processes, such as a court action or administrative proceeding, to resolve their disputes. . . . The arbitration shall be administered by the American Arbitration Association under its Commercial Arbitration Rules, and the Consumer Related Disputes Supplementary Procedures to the extent applicable, before a single arbitrator who shall be a retired judge or an attorney. . . . THIS ARBITRATION PROVISION IS GOVERNED BY THE FEDERAL ARBITRATION ACT. THIS ARBITRATION PROVISION LIMITS YOUR RIGHTS, AND WAIVES THE RIGHT TO MAINTAIN A COURT ACTION OR PURSUE A A-2982-24 3 CLASS ACTION IN COURT OR IN ARBITRATION, PLEASE READ IT CAREFULLY, PRIOR TO SIGNING. The retail order also provided: In the event that any claims are based on a lease, finance, or other agreement between the parties related to this sale or lease as well as this agreement, and if such lease, finance or other agreement contains a provision for arbitration of claims which conflicts with or is inconsistent with this arbitration provision, the terms of such other arbitration provision shall govern and control. The retail order reflected the purchase of the car as well as a twenty-four- month warranty. Plaintiff used a pen to sign both pages of the retail order. Plaintiff's electronic signature appears on a "Retail Installment Contract" (RIC) regarding the financing of the purchase of the car. The RIC designated plaintiff as the "[b]uyer," Carz as the "[c]reditor-[s]eller," and defendant Credit Acceptance Corporation (CAC) as Carz's assignee regarding the RIC. On its second page, the RIC advised plaintiff he was "not required to purchase . . . [a] service contract as a [c]ondition of purchasin[g] this [v]ehicle on credit " and that "by signing below," he was "indicating that [he] voluntari[l]y elect[ed] to buy . . . [a] service contract." Plaintiff's electronic signature appears below that provision. His electronic signature also appears further down on the same page, A-2982-24 4 beneath an acknowledgment that he had agreed to the terms of the RIC, had received a copy of it with all blanks filled in, had read it, and had understood it. Plaintiff's electronic initials appear on the first page of the RIC underneath each of the following paragraphs: ARBITRATION: This [c]ontract contains an Arbitration Clause that states [plaintiff] and [Carz or CAC] may elect to resolve any dispute by arbitration and not by court action. See the Arbitration Clause on Page 5 of this contract for the full terms and conditions of the agreement to arbitrate. By initialing below, you confirm that you have read, understood and agree to the terms and conditions in the Arbitration Clause. and ADDITIONAL TERMS AND CONDITIONS: THE ADDITIONAL TERMS AND CONDITIONS, INCLUDING THE AGREEMENT TO ARBITRATE SET FORTH ON THE ADDITIONAL PAGES OF THIS CONTRACT ARE A PART OF THIS CONTRACT AND ARE INCORPORATED HEREIN BY REFERENCE. The arbitration clause referenced in that paragraph is entitled "Agreement to Arbitrate" (capitalization modified) and is contained on page five of the RIC. Plaintiff's electronic initials appear below that agreement. The Agreement to Arbitrate advised plaintiff of his "[r]ight to [r]eject" arbitration by submitting "a written rejection notice . . . [stating he was] rejecting this Arbitration Clause." The Agreement defined "dispute" as: A-2982-24 5 A "Dispute" is any controversy or claim between [plaintiff] and [Carz or CAC] arising out of or in any way related to this [c]ontract . . . "[D]ispute" does not include disputes about the validity, enforceability, coverage or scope of this Arbitration Clause or any part thereof (including, without limitation, the Class Action Waiver described in the sixth paragraph . . . the last sentence of the seventh paragraph . . . and/or this sentence); all such disputes are for a court and not an arbitrator to decide. However, any dispute or argument that concerns the validity or enforceability of the [c]ontract as a whole is for the arbitrator, not a court, to decide. The Agreement addressed potential conflicts with other arbitration clauses: In the event there is an agreement [t]o arbitrat[e] claims or disputes that conflicts with this Arbitration Clause, whether such agreement is executed before, at the same time, or after this Arbitration Clause, the terms of this Arbitration Clause shall control any and all Disputes between [plaintiff] and [Carz or CAC]. The Agreement provided that it is "governed by the FAA and not by any state arbitration law." Plaintiff used a pen to sign a "Declaration Acknowledging Electronic Signature Process" (capitalization modified) (the Declaration), which provided: By signing below, I, [plaintiff] . . . hereby state that: 1. I read, understood, and agreed to the eSign Consent form and consented to use legally binding electronic signatures to sign all documents necessary to A-2982-24 6 process a retail installment transaction with [Carz] .... 2. I was given the opportunity to review a paper version of the [RIC] I was being asked to sign prior to using electronic signatures to electronically sign the documents. 3. I acknowledge and am aware the [RIC] contains an Arbitration Clause providing that parties to the [RIC], as well as [Carz]'s assignee and others described in the Arbitration Clause, may elect to resolve any dispute by arbitration and not by court action. 4. I was in physical control of the key[]board, mouse or other device to click a button, signature box, or initial box that applied my e-signature to the documents with the intent to sign the documents as if I provided my handwritten signature on documents. 5. I received a fully executed copy of the [RIC]. Plaintiff's electronic signature appears on a "vehicle service contract" concerning plaintiff's purchase of the warranty. The contract identified plaintiff as the "[c]ontract [h]older," Carz as the "[s]elling [d]ealer," and defendant Wynn's Extended Care, Inc. (WEC) as the "[c]ontract [o]bligor." The top of the first page of the contract contained the following information in bold: "THE PURCHASE OF THIS CONTRACT IS NOT REQUIRED EITHER TO PURCHASE OR TO OBTAIN FINANCING FOR A MOTOR VEHICLE." The contract contained the following acknowledgment: A-2982-24 7 I hereby agree to and acknowledge the terms and conditions of this [c]ontract, including but not limited to . . . the "Dispute Resolution" section including the arbitration provision, in "Section 10. OTHER IMPORTANT CONTRACT PROVISIONS/ LIMITATIONS," and have read and understood said provisions, which are incorporated herein by reference. [(Boldface omitted).] The contract's dispute-resolution section provided, in relevant part: 1. ARBITRATION. READ THIS ARBITRATION PROVISION CAREFULLY, AS IT INVOLVES THE WAIVER OF RIGHTS TO ACCESS AND MAINTAIN OTHER AVAILABLE DISPUTE RESOLUTION PROCESSES, SUCH AS A COURT ACTION . . . . SPECIFICALLY, INSTEAD OF SUING IN COURT, DISPUTES ARE RESOLVED THROUGH AN ARBITRATION PROCESS WHERE THE RULES ARE DIFFERENT, AND NEITHER [PLAINTIFF] NOR [WEC] WILL HAVE THE RIGHT TO ACCCESS A JUDGE OR JURY, OR PARTICIPATE AS ANY MEMBER OF A CLASS, AND JUDICIAL REVIEW AND CERTAIN LEGAL RIGHTS, ALONG WITH DAMAGES, MAY BE LIMITED. If a dispute between [plaintiff] and [WEC] arises under the [c]ontract . . . any and all unresolved claims, counterclaims, disputes or controversies . . . , shall be settled exclusively through confidential binding arbitration in accordance with the provisions hereunder and the then in effect [e]xpedited [p]rocedures of either (i) the American Arbitration Association's (AAA) Commercial Arbitration Rules (the AAA Rules) or (ii) the JAMS Comprehensive Arbitration Rules (the JAMS Rules), as elected by whoever first files an action, A-2982-24 8 unless [plaintiff] and [WEC] agree otherwise in a writing signed by both. . . . Notwithstanding the foregoing and without modifying anything herein, this agreement is not intended to and shall not alter, amend or supersede the agreement to arbitration in the [RIC]. In the event that a dispute arises under the [vehicle service contract] between [plaintiff], on the one hand, and [CAC] and [WEC] on the other hand, whether or not [CAC] or [WEC] are named as a party upon commencement of any proceedings or by joinder thereafter, the arbitration provision contained in the [RIC] shall govern the resolution of such dispute. For purposes of clarification, any dispute under this [vehicle service contract] solely between [plaintiff] and [WEC] shall be governed by the arbitration provisions in this [vehicle service contract], and any dispute under this [vehicle service contract] that involves [CAC] shall be governed by the arbitration provisions in the [RIC]. . . . a. Governing Law; Venue; Decision. The arbitration provisions in this [c]ontract shall be governed by the Federal Arbitration Act [(FAA)], 9 U.S.C. §§1[-16] . . . and not by any state arbitration law, and it is expressly agreed that this [c]ontract evidences a transaction in interstate commerce. [(Emphasis omitted).] On November 18, 2024, plaintiff filed a purported class action complaint against defendants. Plaintiff alleged that after Carz had "required [him] to fill out paperwork . . . so that Carz could run a credit check" and after he stated he did not want to purchase the car, a Carz agent had told him "the [v]ehicle was A-2982-24 9 already [his], and that . . . defects would be repaired." According to plaintiff, the Carz agent "then rushed [him] through the signing of several documents, which [p]laintiff presumed to be sales documents." Plaintiff asserted he "was not given copies of the documents or time to meaningfully review the documents and/or have them interpreted into Spanish, his first language." Nevertheless, based on a representation that defects in the car would be repaired before the car was delivered to plaintiff, "[p]laintiff signed the purported sales documents." Plaintiff asserted he had "signed the sales documents in ink with a pen." However, he acknowledged "Carz and [he had] entered into the [RIC] governing the sale and financing of the [v]ehicle" and he had "purchased the WEC Service Contract through [d]efendant Carz." He also alleged Carz had "tricked [him] into digitally signing and executing the" RIC and the vehicle service contract. Plaintiff pleaded several statutory and common-law causes of action. In the fraudulent-inducement count, plaintiff asserted the following: In order to induce the sale of the [v]ehicle and [s]ervice [c]ontract, as well as the execution of the [RIC] and Arbitration Clause included therein, Carz made material misrepresentations to [p]laintiff about the purchases and the [v]ehicle's quality, including that the [v]ehicle was in good condition, was fit for use and merchantable, could be legally driven, and could pass inspection. A-2982-24 10 In lieu of filing an answer, each defendant moved to compel arbitration and dismiss the complaint pursuant to Rule 4:6-2. Defendants relied on the arbitration provisions of the contracts at issue. In opposition to the motions, plaintiff submitted a certification in which he asserted that after a Carz's representative had told him he "could view and test drive the [v]ehicle, . . . [he] was first required to fill out paperwork to authorize Carz to check [his] credit." According to plaintiff, after he "noticed numerous defects with the vehicle," he had stated he did not want to purchase it, but "Carz's representatives told [him] that the vehicle was already [his] and that [he] had already signed for it." He asserted that "[u]nder pressure from Carz's representative and representations that [he] already owned the [v]ehicle, [he] signed the rest of the sales documents." He also certified that he had signed "sales documents" but "only . . . with a pen and was not presented documents to sign electronically." He asserted Carz had not given him "sufficient time to meaningfully review the documents or have them translated into Spanish." After hearing argument on April 14, 2025, the court entered orders and placed a decision on the record granting defendants' motions, compelling arbitration, and dismissing the complaint without prejudice. The court recognized plaintiff's contention that "the entirety of the contract documents A-2982-24 11 presented to the [c]ourt were induced by fraud" but found plaintiff clearly was "not attack[ing] the validity of the arbitration clause[s themselves]" and that the arbitration clauses "ha[d] broad language covering all disputes as set forth in [p]laintiff's complaint." The court also concluded the FAA governed each of the arbitration provisions and that "claims of fraud in the inducement of the contract as a whole are for arbitrators to resolve under the FAA," citing Goffe v. Foulke Management Corp., 238 N.J. 191, 209 (2019). The court rejected plaintiff's argument that it should not compel arbitration given the purportedly different arbitration procedures set forth in the contracts. This appeal followed. II. We review de novo a trial court's decision granting or denying a motion to dismiss submitted pursuant to Rule 4:6-2. See ACLU of N.J. v. Cnty. Prosecutors Ass'n of N.J., 257 N.J. 87, 100 (2024). Thus, "we 'owe[] no deference to the trial court's legal conclusions.'" Borough of Caldwell v. Cozzarelli Cirminiello Architects, LLC, 482 N.J. Super. 492, 498 (App. Div. 2025) (alteration in original) (quoting Dimitrakopoulos v. Borrus, Goldin, Foley, Vignuolo, Hyman & Stahl, P.C., 237 N.J. 91, 108 (2019)). A-2982-24 12 "[W]e assume . . . the allegations in the pleadings are true and afford the plead[ing party] all reasonable inferences." Sparroween, LLC v. Twp. of W. Caldwell, 452 N.J. Super. 329, 339 (App. Div. 2017). "In evaluating motions to dismiss, [we] consider allegations in the complaint, exhibits attached to the complaint, matters of public record, and documents that form the basis of a claim." AC Ocean Walk, LLC v. Am. Guar. & Liab. Ins. Co., 256 N.J. 294, 310-11 (2024) (quoting Myska v. New Jersey Mfrs. Ins. Co., 440 N.J. Super. 458, 482 (App. Div. 2015)) (internal quotation marks omitted); see also Myska, 440 N.J. Super. at 482 (finding that in reviewing a motion to dismiss, "a court may consider documents specifically referenced in the complaint 'without converting the motion into one for summary judgment.'" (quoting E. Dickerson & Son, Inc. v. Ernst & Young, LLP, 361 N.J. Super. 362, 365 n.1 (App. Div. 2003), aff'd, 179 N.J. 500 (2004))).1 1 In support of its motion, CAC referenced a "Disclosure Form," containing plaintiff's electronic signature and an acknowledgement that plaintiff had been "given an opportunity to read both sides of the [RIC], which has been completely filled in, and to ask all questions [he] may have concerning the terms and conditions of the [RIC]." We did not consider that document in our review because it was not referenced in the complaint. In contrast, plaintiff referenced in the complaint the RIC, the vehicle service contract, and sales documents he had signed in ink. Accordingly, we considered the RIC, the vehicle service contract, the retail order, and the Declaration. A-2982-24 13 "We review a trial court's order granting or denying a motion to compel arbitration de novo because the validity of an arbitration agreement presents a question of law." Santana v. SmileDirectClub, LLC, 475 N.J. Super. 279, 285 (App. Div. 2023). Similarly, "[t]he interpretation of an arbitration agreement and its enforceability are questions of law that we review de novo." Antonucci v. Curvature Newco, Inc., 470 N.J. Super. 553, 560 (App. Div. 2022). Therefore, we do not afford "special deference to the trial court's interpretation of an arbitration provision, which we view 'with fresh eyes.'" Ogunyemi v. Garden State Med. Ctr., 478 N.J. Super. 310, 315 (App. Div. 2024) (quoting Morgan v. Sanford Brown Inst., 225 N.J. 289, 303 (2016)). "[T]he United States and the State of New Jersey have declared policies favoring arbitration," Grandvue Manor, LLC v. Cornerstone Contracting Corp., 471 N.J. Super. 135, 145 (App. Div. 2022), through the FAA and the New Jersey Arbitration Act (NJAA), N.J.S.A. 2A:23B-1 to -32; see also Atalese v. U.S. Legal Servs. Grp., L.P., 219 N.J. 430, 440 (2014) ("The [FAA] . . . , and the nearly identical [NJAA] . . . , enunciate federal and state polices favoring arbitration."). Thus, in considering motions to compel arbitration, "we are mindful of the strong preference to enforce arbitration agreements, both at the state and federal level." Lahoud v. Anthony & Sylvan Corp., 481 N.J. Super. A-2982-24 14 29, 40-41 (App. Div. 2025) (quoting Hirsch v. Amper Fin. Servs., LLC, 215 N.J. 174, 186 (2013)). Nevertheless, "[a]rbitration's favored status does not mean that every arbitration clause, however phrased, will be enforceable." Walker v. Route 18 Auto Grp., LLC, 484 N.J. Super. 176, 184 (App. Div. 2025) (alteration in original) (quoting Atalese, 219 N.J. at 441). "[A]rbitration is fundamentally a matter of contract" under the FAA and NJAA. Antonucci, 470 N.J. Super. at 561. Therefore, "[a]rbitration agreements are subject to customary contract law principles." Lahoud, 481 N.J. Super. at 41. "An agreement to arbitrate, like any other contract, must be the product of mutual assent, as determined under customary principles of contract law." Antonucci, 470 N.J. Super. at 561 (quoting Atalese, 219 N.J. at 442) (internal quotation marks omitted). An arbitration agreement may "be invalidated by generally applicable contract defenses, such as fraud, duress, or unconscionability." Arafa v. Health Express Corp., 243 N.J. 147, 165 (2020) (quoting AT&T Mobility LLC v. Concepcion, 563 U.S. 333, 339 (2011)) (internal quotation marks omitted). "An arbitration provision is not enforceable unless the consumer has reasonable notice of its existence." Wollen v. Gulf Stream Restoration & Cleaning, LLC, 468 N.J. Super. 483, 498 (App. Div. 2021). However, "a party A-2982-24 15 may not claim lack of notice of the terms of an arbitration provision for failure to read it." Santana, 475 N.J. Super. at 286. Therefore, "in the absence of fraud, one who does not choose to read a contract before signing it cannot later relieve himself of its burdens." Moreira Constr. Co. v. Moretrench Corp., 97 N.J. Super. 391, 394 (App. Div. 1967); see also Skuse v. Pfizer, Inc., 244 N.J. 30, 54 (2020) (same). "When reviewing a motion to compel arbitration, courts apply a two- pronged inquiry: (1) whether there is a valid and enforceable agreement to arbitrate disputes; and (2) whether the dispute falls within the scope of the agreement." In re Est. of Hekemian, 484 N.J. Super. 458, 467 (App. Div. 2026) (quoting Wollen, 468 N.J. Super. at 497). In opposing defendants' motions to compel, plaintiff did not contend the parties' dispute fell outside the scope of the arbitration agreements. Instead, he challenged the validity and enforceability of those agreements. In the complaint, plaintiff claimed he was fraudulently induced into the entering transactions at issue. He based that claim on his allegation that "[i]n order to induce the sale of the [v]ehicle and [s]ervice [c]ontract, as well as the execution of the [RIC] and Arbitration Clause included therein, Carz made material misrepresentations to [p]laintiff about the purchases and the [v]ehicle 's A-2982-24 16 quality." The FAA requires "a claim of fraud in the inducement of a contract as a whole[,] rather than fraud in the making of the arbitration agreement itself[,] . . . be resolved by the arbitrator." Goffe, 238 N.J. at 208-09 (citing Prima Paint Corp. v. Flood & Conklin Mfg. Co., 388 U.S. 395, 403-04 (1967)). Thus, because plaintiff's fraudulent-inducement claim was based on a challenge "about overall contract validity" and not a specific challenge to "the arbitration agreement[s themselves]," that claim, as the trial court correctly held, must be determined by an arbitrator. Id. at 195; see also Van Syoc v. Walter, 259 N.J. Super. 337, 339 (App. Div. 1992) ("[A]bsent a claim of fraud directed at the arbitration clause itself, a claim of fraud in the inducement of the contract is a matter for the arbitrators."). At oral argument before the trial court, plaintiff's counsel challenged the contracts at issue based on a theory of fraud in the execution. He based his fraud-in-the-execution theory on plaintiff's allegations that: Carz "required [him] to fill out paperwork first so that Carz could run a credit check"; after he stated he did not want to purchase the car, a Carz agent told him "the [v]ehicle was already [his], and that . . . defects would be repaired"; the Carz agent "then rushed [him] through the signing of several documents, which [p]laintiff presumed to be sales documents." A-2982-24 17 Plaintiff argues the court, and not an arbitrator, should decide his purported fraud-in-the-execution claim, citing MZM Construction Co. v. New Jersey Building Laborers Statewide Benefit Funds, 974 F.3d 386 (3d Cir. 2020), and Knight v. Vivint Solar Developer, LLC, 465 N.J. Super. 416 (App. Div. 2020). The Third Circuit in MZM Construction described the difference between fraud-in-the-inducement and fraud-in-the-execution claims: Fraud in the inducement occurs when someone signs the document they intended to sign, but their assent was induced by a material misrepresentation about facts external to that document. For example, if a party misrepresents that the price of cheese will increase to induce someone into signing a contract to buy milk in bulk, that is fraud in the inducement. But if a party assures its counterparty that it is signing a contract for cheese when it is in fact a contract for milk, that is fraud in the execution. [MZM Constr., 974 F.3d at 405 (citations omitted).] Even a generous reading of the complaint and the certification plaintiff submitted in opposition to the dismissal motions does not support a fraud-in- the-execution claim. Those documents demonstrate that after the Carz agent allegedly told him "the [v]ehicle was already [his]," plaintiff signed documents he understood to be "sales documents" and plaintiff understood he was purchasing a car. In plaintiff's merits brief, plaintiff's counsel asserts the credit- check paperwork plaintiff signed was the RIC. That assertion is not supported A-2982-24 18 in either the complaint or plaintiff's certification. The trial court correctly rejected counsel's fraud-in-the-execution argument. Plaintiff contends the court should not have compelled arbitration due to purportedly "[c]onflicting [t]erms" in the contracts' arbitration provisions. That argument is without merit. The contracts expressly provide that in the event of a conflict, the RIC controls. Although we affirm the provisions of the April 14, 2025 orders compelling arbitration, we vacate the provisions of the orders dismissing the case. Because the arbitration clauses were expressly governed by the FAA, the court should have stayed the case, not dismissed it. See Antonucci, 470 N.J. Super. at 567 (holding "a court action should be stayed if the action involves 'any issue referable to arbitration'" under the FAA (quoting 9 U.S.C. § 3)). Accordingly, we vacate the dismissal provisions of the orders and remand the case for entry of an order staying the case in the Law Division pending arbitration. Affirmed in part; vacated in part; and remanded for proceedings consistent with this opinion. We do not retain jurisdiction. A-2982-24 19