Partridge v. American Hospital Management Company, LLC, Civil Action No. 2017-0248

Partridge sued American Hospital Management Co., LLC (LLC), American Hospital Management Co., LMT (LMT), and Randall Arlett for unpaid wages, breach of two employment agreements, DC wage-law violations, and fraud.
Defendants moved to dismiss and to compel arbitration based on an arbitration clause in the First Agreement; an errata sheet later clarified the motion was on behalf of all three defendants.
Parties mediated and signed a settlement incorporated into a consent decree requiring an initial $50,000 payment and monthly payments totaling $150,000; Partridge claims no initial payment was made.
After Post‑settlement disputes, court revived pre‑settlement motions: Plaintiff’s motion to strike the errata sheet, Defendants’ motion to dismiss/compel arbitration, Plaintiff’s summary judgment motion, and defense counsel’s motion to withdraw.
Court denied motion to strike the errata sheet, denied dismissal of Arlett and denial of arbitration (finding waiver), granted summary judgment for Partridge on breach against LMT only, denied summary judgment on other claims, and granted defense counsel’s withdrawal; LLC and LMT must obtain new counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motion to strike errata sheet	Errata improperly joins LMT to motion to dismiss; prejudices Partridge	Errata corrects oversight; no bad faith; should be allowed	Denied — court exercised discretion to permit errata; no undue prejudice
Dismiss Arlett under Rule 12(b)(6)	Arlett is liable (alter ego; operational control; signed agreements)	Arlett did not sign personally; corporate separateness precludes personal liability	Denied — allegations suffice to infer alter ego, employer status, and meaningful participation in alleged fraud
Compel arbitration (FAA)	Arbitration clause covers disputes; compel arbitration of claims against LLC and LMT	Plaintiff: waiver, some claims not arbitrable, prohibitive fees; Defendant: enforce clause	Denied — defendants waived right by active litigation, consenting to court consent-decree jurisdiction and participating in settlement process
Summary judgment on breach, DCWPCL, and noncompete	Entitled to summary judgment: breach by LMT and others, DC wage-law violations, noncompete unenforceable	Dispute about which entity bound, whether employment occurred in D.C., and ambiguity of Second Agreement	Granted in part — summary judgment for Partridge only on breach against LMT; denied on other defendants and on DCWPCL and noncompete due to factual/ambiguity issues

Canady v. Erbe Elektromedizin GmbH, 307 F. Supp. 2d 1 (D.D.C. 2004) (motion to strike reviewed under district court discretion)
Jackson v. Finnegan, Henderson, Farrabow, Garrett & Dunner, 101 F.3d 145 (D.C. Cir. 1996) (court may deny supplements to promote fair administration)
Cohen v. Bd. of Trustees of the Univ. of the Dist. of Columbia, 819 F.3d 476 (D.C. Cir. 2016) (district courts have discretion to extend deadlines)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must raise claim above speculative level)
Moses H. Cone Mem'l Hosp. v. Mercury Constr. Corp., 460 U.S. 1 (1983) (policy favoring arbitration; defendants may assert defenses like waiver)
Dean Witter Reynolds, Inc. v. Byrd, 470 U.S. 213 (1985) (district court shall direct arbitration when dispute is referable)
Khan v. Parsons Global Servs., Ltd., 521 F.3d 421 (D.C. Cir. 2008) (waiver of arbitration can result from active litigation conduct)
Zuckerman Spaeder, LLP v. Auffenberg, 646 F.3d 919 (D.C. Cir. 2011) (forfeiture vs waiver analysis for late arbitration assertions)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standards; burden-shifting)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (genuine dispute and materiality standards for summary judgment)