In Dotson v. Amgen, Inc., a California appellate court confirmed that mandatory arbitration agreements with discovery limitations are enforceable provided that they also give the arbitrator the authority to allow further discovery upon a showing of need. Darrell Dotson, Amgen’s former in-house attorney, challenged the enforceability of the arbitration agreement he signed at inception of employment claiming that its limitation that each party could take only one deposition, and other clauses, rendered the agreement unconscionable. The court rejected Dotson’s argument, citing the California Supreme Court’s prior observation that “discovery limitations are an integral and permissible part of the arbitration process” and the fact the arbitrator retained the discretion to allow additional discovery “upon a showing of need.”