After successfully defending apartment developers from bank’s judicial foreclosure action, obtaining dismissal of judicial foreclosure claims by demurrer, and winning attorney’s fees. When the bank then sought to compel judicial reference of the developers’ lender liability cross-complaints, notwithstanding opposition based upon interpretation of ADR agreement and bank’s waiver through years of inaction, the trial court erroneously ordered the parties to arbitration. Mr. Zepeda then obtained peremptory writ from Court of Appeal reversing order compelling arbitration, securing jury trial of lender liability claims, allowing both cases to be settled at beginning of trial.