The employer had successfully compelled individual PAGA claims to arbitration, but the arbitration fees were paid 14 days late due to a holiday-period administrative processing delay. Plaintiff moved to vacate the order under CCP § 1281.98, citing the then-universal appellate authority holding that any late payment — regardless of reason — automatically forfeited arbitration rights. The California Supreme Court decided Hohenshelt v. Superior Court (2025) 18 Cal.5th 310 while the motion was pending. The supplemental brief I drafted applied Hohenshelt's equitable framework: the majority opinion required forfeiture only for willful, grossly negligent, or fraudulent nonpayment. The brief distinguished every unfavorable appellate authority that Hohenshelt had disapproved — Gallo, Espinoza, De Leon, Williams, Doe v. Superior Court, Colon-Perez, and Sanders — and demonstrated through internal communications and payment records that the 14-day delay was attributable to a holiday-period invoice processing failure, not strategic conduct. The court adopted the analysis and denied the motion to vacate.