David Borgen and Joseph Jaramillo, along with co-counsel Herbert Eisenberg of Eisenberg & Schnell, LLP, filed a brief in the Second Circuit in Raniere v. Citigroup, Inc., et al., on behalf of the National Employment Lawyers Association and other amici addressing the enforceability under the National Labor Relations Act and Fair Labor Standards Act of a class/collective action waiver in an arbitration agreement imposed as a condition of employment on its employees.