Many of us long time Host Parents received an email today with the disarming subject line: “Tell Us About Your Au Pair.” The email is actually asking us to participate in a short survey about the Au Pair Program.
The email does note that the information “will be helpful to au pairs in pursuing the litigation.” Ahem.
The survey is quite short. They really just want to know when you had an au pair and which kind (e.g., regular or extraordinaire). The trick questions are towards the end, where you’re asked:
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As we all know, the organization that determines the baseline rate of pay for Au Pairs is the US State Department.
You may also have received another email from your Agency reminding you that they really didn’t want to release your private information to the litigators, but were required to.
Just fyi.
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Actually, it’s the DoL and the FLSA that sets the labor rate. The au pair agencies are required to determine the rate for each area they operate based on FLSA. I haven’t even started to dig into the FLSA to figure out what that should be for the DC Metro areas. Maybe after dinner.
Title 22 Chapter I Subchapter G §62.31 Au pairs. (j) Wages and hours. Sponsors shall require that au pair participants:
(1) Are compensated at a weekly rate based upon 45 hours of child care services per week and paid in conformance with the requirements of the Fair Labor Standards Act as interpreted and implemented by the United States Department of Labor. EduCare participants shall be compensated at a weekly rate that is 75% of the weekly rate paid to non-EduCare participants;
So the question is—
Is it better to answer the survey with correct information (State Dept.) or to ignore the survey altogether? If we answer correctly, we help to disarm the case, right?
The rate you pay your aupair (and the whole aupair exchange program) is set by the federal government based on federal minimum wage and a minimal amount for living expenses. In reality, the almost $200 per week is for SPENDING MONEY because you are paying their living expenses, their education expenses and their transportation, which in Seattle is worth about 4K per month. The truth is if these attorneys really cared about the aupairs they would go directly to the federal government and lobby on their behalf. These lawyers are NOT helping aupairs, they are looking to make money for themselves.
I just got this email yesterday and sent back a nasty email to the law firm. I think we should inundate their inbox with our opinion of their lawsuit!
It is so unjust for the remainder of au pairs and families that may be impacted by this litigation in the future. After all, it is a great cultural exchange for both the families and the au pairs. It is the cheapest way one can travel here and see the US for 13 months (if they travel after their year), and of course it is affordable, legal childcare vs hiring someone illegally without the support. Granted- we all know there are plusses and minuses to the program, but as a whole it is worth keeping. If they win the lawsuit, it is a loss for all future au pairs as there would be little need to have the program if we were to all pay the ‘going rate’ for the childcare coupled with paying room and board for an individual.
So- there’s my two cents! I am incensed that this lawsuit was brought! Arghhh.
Lets all email the lawfirm!!
I don’t think this is anything to “beware” or get especially alarmed about, or that there are trick questions. Presumably the agencies will either conduct their own survey, and/or they’ll use discovery to gain access to the answers collected by the APs’ attorneys. If the majority of responses indicate that, across all host families, (a) the number of hours worked varies significantly, and (b) the total compensation (beyond stipend, perks like phone, gas allowance, car privileges, vacations, value of room/board), varies significantly, then it would ultimately undermine the APs’ attempts to be certified as a class, and their argument that the price is fixed. And if those responses also suggest that (c) there’s a significant cultural exchange component to the APs’ experience (such as being included in family dinners and activities), it pokes lots of holes into the argument that they’re domestic workers who should be paid minimum wage.
Right now, there’s no one representing the interests of HFs in this litigation. Participating in this survey might be the only opportunity to have a voice. I don’t want to see the cost of the program increase – but I’m not so sure that the APs and their attorneys are necessarily our enemy here.
I disagree- participating in the survey does not give us a voice!!! It is paid for and run exclusively for the use of the plaintiffs!! quite frankly, there is no way of knowing if their responses will ever be truly counted. It is a tool in their litigation arsenal and they are only looking for the answers that will boost their lawsuit. Hence the multiple choice.
How do you plan on responding in a way that communicates, as you listed (a) hours worked (b) total compensation (c) cultural exchange, when the survey does not allow us to give voice to elaborate on these areas? This is a multiple choice survey that focuses narrowly on STIPEND, not total compensation or hours or cultural exchange benefits.
If we want a voice, we need to create our own channel. One that is not controlled by and at the whim of an entity with their own agenda.
Please be cautious. Unless you know the law in this area, you may assume information you are giving is helpful to the agencies or not helpful to the APs but there’s a good chance you are wrong For example, perks like car privileges, phone, gas etc (and even room and board) are not likely included in regular rate of pay under the FLSA, so they don’t matter to what’s being litigated. They do not help the HF cause here. These are very complicated legal issues that are rarely aligned with common sense.
Trust me the APs and their attorneys are enemies of the continuation of the program. There is no doubt about that.
I totally agree with fortysomethings response. I’m also
A lawyer but don’t practice in that area. I do, however know that the ‘survey’ is only meant to help those suing the agency’s and possibly host families next
Another lawyer in agreement: please don’t try to “help” as that will likely not be helpful. Good intentions are not a substitute for legal expertise. Either ignore the survey or answer it honestly.
We all received the State Dept regs when we joined the program and so did the APs. We all saw that the $195 plus room and board is required by law.
WarmStateMomma, do you have a link that shows the $195.75 is (the minimum) required by law? I haven’t been able to find any reference to that specific number (or the formula by which it’s reached) anywhere in the State Dept regulations (which just reference FLSA) or in my agency contract.
And yes, obviously the only choices are to ignore the survey or to be honest. I would never suggest doing anything other than answering honestly, and I haven’t done so here.
I’ve also been careful not to tell anyone what to do with respect to the survey. Each HP needs to make his/her own decision, and even lawyers can disagree about what that might be, depending on personal circumstances and/or feelings about the program. There’s a lot of chatter and instruction not to “help” or participate, here and elsewhere. That’s fine, but there’s a valid counter-argument and perspective, and I don’t believe suggesting that only one side is informed by legal expertise (and the other is just naive good intentions) is especially helpful in sorting through this mess.
DoS regulations or no, the agencies are already throwing HFs under the bus in their filings to date, arguing that we were the employers so should have known to pay state/local minimum wage (as our contracts direct us to comply with all state/local laws) – and even though the regs provide that sponsors are the ones required to ensure compliance.
For stipend I answered “at least $200” and in the free-form box I listed out the many benefits, and pointed out that the full stipend was paid regardless of sick days, holidays, vacations, late start, or early dismissal. There is no way this survey on its own can prove that the au pairs weren’t paid enough (whatever “enough” is) when it doesn’t ask how many hours your au pair worked. I don’t see how it could help show that the agencies colluded to suppress wages, rather than that each agency was following the the State Department rules and communicating them to the host families.
I feel really sad that this lawsuit could destroy the au pair program, but at the same time, isn’t it ultimately the State Department that is responsible for the terms of the program, not the individual agencies (which are, of course, all designated by the State Department)? If there is any party at fault for suppressed wages, isn’t it the State Department?
When people ask me why anyone would want to be an au pair, my standard answer is that it is a great, affordable way to live in a foreign country. Plus, if you would rather do a “semester abroad” or a whole degree program, rather than get paid $200 a week, you need to pony up full price out-of-state tuition on the front end – no loans, even. The vast majority of au pairs come from families that would not be able to foot the bill for an American college experience. I think the most comparable alternative is the J-1 high school exchange, and the fees for participation in those programs are generally in the thousands (and they don’t work or get paid).
(To clarify my comment above, these specific AP PLAINTIFFS (not all APs obv) and their attorneys are enemies of the continuation of the program).
I posted this point below in the “Latest Salvo” post, but worth repeating up here (with a little more detail now that i’m on a computer and not my phone):
It occurred to me upon further reflecting that this is probably discovery for the class certification phase (on the collusion issue) and not the actual underlying issue. They do class cert stuff first. **Texas HM, from our discussion earlier, this is prob why they are only asking HOW we learned of the stipend and not what you paid etc! (i had a lightbulb moment on this while walking to my car. lol)
To get class cert, they will need to show commonality – probably specifically that we all learned of the stipend rate from the agency (vs a friend or the regs or another source). If we didn’t learn of the stipend from the agency, we all don’t have that in common (which if true, would make it hard to show the agencies colluded (successfully) to keep AP pay down). Lack of commonality makes it really hard to get class certification.
If this is the case (any class action lawyers here want to chime in? I know just a bit but am not an expert) possibly all the more reason to ignore and not reply (if only a small percentage reply, it may not be enough to be reliable data – again any class action experts have an opinion?). Or Everyone just put something different that “learned it from the agency.”. Lol.
Because here’s the key part: without class certification, the power of this case and the chance it will have any lasting impact on the AP program is significantly decreased. Then it would be just a bunch of single plaintiff cases with minimal damages/publicity, etc.
I continue to believe not answering is best. Because I’m sort of guessing with the above analysis.
But also, I STILL didn’t get the survey (are they excluding lawyers!?). Anyone else not get it?
I’ve heard from someone who got it that you can not answer and then actually unsubscribe.
(this may show up twice here eventually. i accidentally put a space between “Forty” and “something” the first time I tried to post, so i think the system thinks I”m new. Apologies).
I posted this point below in the “Latest Salvo” post, but worth repeating up here (with a little more detail now that i’m on a computer and not my phone):
It occurred to me upon further reflecting that this is probably discovery for the class certification phase (on the collusion issue) and not the actual underlying issue. They do class cert stuff first. **Texas HM, from our discussion earlier, this is prob why they are only asking HOW we learned of the stipend and not what you paid etc! (i had a lightbulb moment on this while walking to my car. lol)
To get class cert, they will need to show commonality – probably specifically that we all learned of the stipend rate from the agency (vs a friend or the regs or another source). If we didn’t learn of the stipend from the agency, we all don’t have that in common (which if true, would make it hard to show the agencies colluded (successfully) to keep AP pay down). Lack of commonality makes it really hard to get class certification.
If this is the case (any class action lawyers here want to chime in? I know just a bit but am not an expert) possibly all the more reason to ignore and not reply (if only a small percentage reply, it may not be enough to be reliable data – again any class action experts have an opinion?). Or Everyone just put something different that “learned it from the agency.”. Lol.
Because here’s the key part: without class certification, the power of this case and the chance it will have any lasting impact on the AP program is significantly decreased. Then it would be just a bunch of single plaintiff cases with minimal damages/publicity, etc.
I continue to believe not answering is best. Because I’m sort of guessing with the above analysis.
But also, I STILL didn’t get the survey (are they excluding lawyers!?). Anyone else not get it?
I’ve heard from someone who got it that you can actually unsubscribe from getting the emails.
I agree – I think this is for the certification phase. Right now, the commonality argument seems strong to me, which is why I’m considering (just considering!) the idea that responding may not be a bad strategy for host families. Commonality doesn’t implicate how we learned about the stipend; it’s a showing that the APs all suffered the same harm/injury. Based solely on the DoS regulations (same stipend, same hours, same room/board), commonality looks pretty easy to demonstrate (in my opinion).
For that reason, I wouldn’t answer the multiple choice questions; far too easy to misrepresent what those data mean. For the open-ended question at the end, though, I assume (and certainly hope) that this would all be part of the agencies’ discovery, and they’ll have full access to these responses. If the majority, or even a significant percentage, of responses indicate that the commonality suggested by the DoS regulations doesn’t actually exist – then it would undermine the argument for certification. As you said, that would be a huge blow to the lawsuit, and perhaps end it altogether. Best case scenario, the host families who DO respond are ones who regularly use fewer than the full 45 hours, who pay over the stipend (and/or regular bonuses that increase compensation), and provide other parts of an overall compensation package (phone, gas, food budget beyond what’s available in the kitchen, regularly included in family/cultural activities and events, etc., that demonstrate that these are not mere employees but are actually cultural exchange visitors who are treated as family members).
I do think they need commonality for each and all of their different claims – including the collusion/price fixing claim. As noted, I’m not a class action attorney (have only done a little work in this area). So please take the following analysis with that understanding.
These few APs claim that they should be able to represent ALL APs (during a certain timeframe, from the named agencies) in a case of collusion/price fixing based on allegations that the agencies conspired to keep wages low (and other claims, such as wage claims under the FLSA). I would think (but am not sure) that part of that collusion case (as to liability and/or damages) would be that all/most HFs (a) learned of the stipend rate from the agencies and then (b) also relied on that information that they got from the agencies to set the stipend for their respective APs.
If they are able to show this – through sufficient helpful (to them) responses to the survey – I’d expect that they will likely make the argument that all the APs in the putative class are common enough on the price fixing claim that they should be a class (vs. individual claims).
If (a) the results of the survey show that enough of us learned from different places (not the agencies/sponsors or their literature) or (b) they get insufficient results for a reliable sample bc not enough of us reply, I think there is an argument (for the agencies) that there is insufficient commonality and it should NOT proceed as a class action (and as noted, defeating class cert would be a huge blow to the efforts of these plaintiffs and those who are backing them in this attempt to shut down the program).
I am not sure they will have to share all the results of the survey with the agencies. It may depend on how/if they intend to use the results. It’s not like “regular” discovery (though I am not sure about the details of this).
I have not yet received the survey (which is kinda weird), and am only going off I’ve seen here, though… tempted to go pull all the briefing and filings from the docket!
Just received our emai/surveyl today. We’ve also hosted with multiple agencies over the years and it asked us to fill out the survey for each AuPair we’ve hosted and based on each Agency. But I didn’t see where you could specify which AuPair or which Agency.
To me, that is a concern, because some AuPairs worked much less hours than others, but each were compensated the stipend plus “perks” (phone, car, inclusion in family events, family travel, family excursions, etc.) and there seems to be no good way to capture that.
I am reading this survey trying to figure out how to accurately capture what you can’t list here, for example, the perks I listed above, or wear and tear on our vehicles, damage to our home/car/appliances etc.
There are so many facets to this and clearly the survey is very pointed and aims only to fulfill a specific goal for the Plaintiff’s.
If I cannot respond accurately and responsibly so I even respond at all?
Fortysomething HM, did you check your spam folder? Mine ended up there (I’m also a lawyer)
I did check spam…. Still no survey! Kind of odd…..
We haven’t gotten one either. Maybe depends on the agency?
My friend from CC who lives in my town got one (I’m also CC, in the same cluster). Maybe they are sending it out in staggered bunches.
Lawyer here. I received it the email from that fake group “Au Pair Information” or whatever it was. I only received the request with respect to one agency but I’ve hosted through multiple agencies. Not sure why.
I spoke with a VP at our agency yesterday regarding the possibility of the agency sending another email blast to families regarding the survey and although they legally cannot advise families against filling out the survey, we have interpreted it correctly that it is fishing to build the case for the plaintiffs and seek class certification. Responses will be interpreted with that bias.
I also received an email yesterday from my agency saying that the court has now ALSO ordered the agencies to disclose the names and contact information for current and former au pairs so that counsel can contact them.
The email says, “It is possible that, once we provide the contact information as required by the Court, your current and/or former au pair(s) could be contacted by an attorney for the plaintiff au pairs with a notice of his or her right to join the lawsuit as part of a ‘class’ against the sponsor defendants.”
I don’t think that this class action suit is a good idea for anyone, but I’m curious about the legal logic. In fact we DID most of us truly learn of the stipend amount from the agencies–who else would we learn it from? The agencies, in turn, communicate it as the federally determined amount, as I recall. What is the definition of price fixing? If there is a regulation determining stipend, isn’t it the US gov’t that is doing the fixing??
Unfortunately, the plaintiffs are arguing (and the Court agreed with them in the motion to dismiss) that the language from the applicable regs state that the government sets only a minimum weekly stipend.
They are arguing that we learned the amount from the agencies, but I’m guessing I’m not the only one that learned about AP requirements from a Google search, the US State Dept website, etc.
If there is any price fixing, it seems to me to be on the fees families pay to the agencies. They are all about the same.
The USG setting a floor for stipends is like setting a floor on hourly wages (aka the minimum wage). People may disagree with whether it is a good policy but it’s not price fixing just because employers can pay more. I don’t think this argument is a winner for the plaintiffs but I haven’t been following the case too closely.
I too learned about the regs from the SD website. Prior to looking at agency websites…
So, would it ultimately help the program survive if host families who use much less than the 45 hours respond? $200 a week for 15-20 hours satisfies minimum wage.
And, is this suit against the agencies? Is there a chance that it would result in an audit or transparency about where there fees go? That would be truly illuminating. Many HF’s have wondered how he agencies justify taking 60% as much compensation as the APs they’re sponsoring. (45 hours a week vs 25-50 hours absolutely total for the year.). Plus, if some agency fees went to APs as more compensation, one could argue that overall AP qualify would improve and overhead/ rematch headaches would decrease.
Nothing that anyone replies to THIS SURVEY will help the defendants. It is being run by the plaintiffs and as such, they will not be using any results that aren’t to their advantage.
Both host families and au pairs pay fees to participate in the program. Au pair fees are based on their country of origin. Fees cover travel, orientation, rematch, sevis fees, counselor salaries, administration fees for the program and other associated costs. As a former counselor we our salaries were quite low and our hours were quite long. We were tasked with paying for monthly cluster meetings with au pairs as well as paying to attend annual training conferences. Agencies do very well with their profits.
Actually, I realized that I underestimated the agency time by a whole order of magnitude- with training school, interviews, etc the time is more likely in the hundreds of hours. Both points still stand, I think. That the agencies seem to make/ keep more money than you’d think in a “transparent and free?” Market, and that more wages would yield better au pairs and less rematches. Anyone with more information feel free to correct me – LCCs, state department employees, economists, lawyers…
As it stands now it is definitely a volume business and Reluctant Grownup if you do the math I think you will see the agency comp is even higher than you thought.
AP minimum stipend x 51 weeks = $9,983.25 so roughly $10K a year
Agency match fees, hosting fee, travel fees, etc = $8-9K a year
It’s almost the same! Now yes, we do provide a lot more to the APs above and beyond but I was talking with my AP last night about all this and realized that in having hosted now for going on 7 years I have paid a TON in agency fees over the years!
6 years of agency fees averaged at $7500 a year = $45,000! We have had ONE burnout rematch and the LC was horrible and we ended up taking a break from the program/nightmare for 6 months to recover. We have paid close to $50K for WHAT?! And that doesn’t include current AP so that is for 4 APs! It is clear to me that those of us like the folks on this blog (invested, caring, long term host families) clearly fund the hot mess that is a large portion of this program. CCAP for whatever reason thinks its acceptable to charge almost as much for extension terms as they do upfront (no CCAP, taking $1-2K doesn’t cut it – look at Interexchange and others which at last glance are about half as much for year two) – clear ploy to profit on the bond formed with the existing family and keep margins high for extension terms which are essentially straight profit (no additional plane tickets, no orientation and you pay my LC $240 a year to cover my family so save me the sales pitch on your overhead and what it takes to run this program in year two).
I don’t know how any agency expects this program to essentially police itself from the field. Paying LCs $15-20 a month per family, nothing for cluster meetings or mediation sessions – how is that a business model for success? I keep waiting for one agency to figure it out and hire someone with the proper experience and pay them properly so I can watch them capture the whole HF market here in a year or two at the most. Our LC isn’t bad at all but there is so much potential for value add/impact in that role and I have yet to see it happen (and we have been with 3 agencies over the years and have had now 6 LCs in as many years and the current LC we have had for 2+ years so check that math!)
I wade through profiles every round amazed at the poor judgment and limited screening and can’t help but think if they would screen harder on both sides their expenses would be dramatically lower, drama/bad press lower and who knows? We might even pay a little more!
This lawsuit is killing my hosting mojo!
Yes, TexasHM!! This is *exactly* where I come out, after having read up on the lawsuit (including the complaint and most recent order denying the motion to dismiss) and thinking through all of the issues. I don’t want the program to end; having an AP is pretty much the only cost-effective way I’ve found for us to get the type of hours/flexibility that we need (and we consistently use WAY under the 45 hours, so I actually feel totally comfortable with what we pay).
BUT, as it currently operates (at least with the agency I know), the program is a sham. The agencies are getting HFs to sign up with the “affordable, reliable childcare” pitch, and the APs to sign up with the cultural exchange/travel the US pitch. Too many HFs are expecting mature, experienced nannies – and too many APs are coming for the wrong reasons, and enabled to use HF just to get here and then leaving them high and dry because the gig is too hard, the location is too remote, or whatever. Far, far too many bad (or at least misguided) APs are allowed to rematch. The agencies aren’t doing their jobs on *either* side of the ledger – and given the level of incompetence I’ve witnessed, the fees I’m paying are being grossly misspent.
The program needs reform, or perhaps a complete overhaul. As a starting point, the agencies need some accountability; as far as I can tell, there’s none right now, particularly when they can boot a HF for any reason. I don’t know that this lawsuit is the way to get to some needed changes (and I certainly don’t believe that back pay is going to help), but something’s got to give, as the current situation is not sustainable.
I agree that agency fees are very large, especially when you compare them to the stipend. I also agree that in my eight years of hosting, I haven’t found the agencies to provide a particularly large amount of value. However, if you do the mental exercise of starting your own agency (and while now is not an auspicious time to do so, you certainly could).
A few numbers I thought about: agencies are willing to pay three to $500 if you successfully refer host family. That means, on average, their marketing cost for acquiring a new family must be more than $500. They also need to provide transportation and orientation in New York. I’ve never been impressed with the quality of the facilities or the facilitators. However, if I was putting together a similar program from scratch, I doubt I could bring someone from another country, transport them from the airport, I have educational programs all day, for less than 1000 to 1500 per person. There’s also another 500 to 1000 for the plane ticket. You need to pay someone in the home country to screen applicants come and interview them, scan in their applications to create a profile, etc. Of course we all think they could do a better job of that, but even the job that they are doing must cost at least $500 per applicant.
Now, the agency also needs to maintain an office staff who is available to respond to emergencies. And they must pay for the local agency. Again, these are not terrifically expensive but they contribute hundred dollars per AP.
The thing is, it’s a big market. Lots of people are spending lots of money on Au Pair childcare. If it was easy to make money because the agencies were vastly over charge everyone, they would be new entrancts to the market. The fact that interexchange doesn’t save you a lot of money, even though they’re nonprofit, is telling.
And let’s not forget the money the AuPairs pay to be in the program! Depending on the agency those fees can be pretty high!
Agreed Dorsi, just saying I think costs are high because screening is poor on both sides. Most agencies use recruiters on the AP side. Yes, RECRUITERS! It’s no wonder the APs get sold – they literally get sold and then recruiter sells them to agencies. CCAP is the only agency that I know of that actually has direct staff in the countries interviewing the candidates. Expert does it via Skype.
For the plane tickets agencies don’t pay those! We pay orientation to home, APs actually pay thousands to get in program and they are told it covers their plane ticket/orientation etc so basically both sides pay so I’m not sure the overhead is as much as you think.
I honestly think the overhead is in rematch. Last minute plane tickets home, refunding host families after burnout matches, paying LCs to house (though that’s not much) etc. Especially when you consider that happens after orientation (largest agency expense).
To your point – look at IEs extension rates – half the regular rate! That gives insight into what a successful year likely requires (add some for orientation maybe).
Just saying I think successful matches are subsidizing a TON of failed ones. Drive down that, everybody wins.
I recommend not responding to the survey. I’ve now received three emails requesting a response, and I will not respond. This lawsuit is no to benefit the au pairs–its for the lawyers (and I am one–although not one pursuing this action). Despite the costs for the au pairs and the costs for the HF, the au pairs get a great educational experience (which is what its supposed to be about for them) and HF get a live-in member of the family to help with their kids. If you currently host an au pair or have in the past, answering this survey will not help you in any way. If you individually believe you are not paying your au pair enough, then increase the stipend. Mine have all been fine with what they’ve earned particularly given the “extras” my family provides, car, most weekends off, decent food and meals, etc.
I have rec’d two emails and just ignored them but just occurred to me to email them back. I think it’s ridiculous first of all – because everyone pays the same stipend, it’s federally mandated as you all have said. AND what if they added up the value of all the other contributions: rent, utilities, use of car, car insurance, medical insurance, cell phone, internet access, food, laundry, and I’m sure I’m forgetting a few things.. plus all the little extras I would provide or give them just because. I suspect these would all add up to “minimum wage”. In fact, I don’t think a person could afford to live like my au pairs did if they worked full time for minimum wage. This just irks me that this is even a case. anyways. just adding my voice and venting a little!
I just tried to unsubscribe to the emails but I had to register in order to unsubscribe. Nope!
Did anyone else receive an email today (6/30) from APC (or their agency)? I think it says that the APs were granted class status. Can someone with a legal background comment on the below paragraph and what this means:
Recently, the judge in the case ordered that the au pairs had met the standard required to conditionally certify a collective action of au pairs under the Fair Labor Standards Act. The order allows the law firm of Boies, Schiller & Flexner, LLP (which represents the au pairs) to send a notice to au pairs who participated or are currently participating in the au pair program that they can “opt-in” to the collective action.
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