California, United States of America
The following excerpt is from Diaz v. Aerospace, B271563 (Cal. App. 2017):
order discovery]; cf. Martinez v. Master Protection Corp. (2004) 118 Cal.App.4th 107, 118-119 [declining to decide whether clause was unconscionable when it limited discovery one deposition, one document request, and other discovery upon showing " 'substantial need,' " but noting it "compound[ed] the one-sidedness of the arbitration agreement"].) The agreement here not only lacked any such relief valve, but it expressly prohibited any additional discovery.
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