Tavasco,

It's hard to know where to start ....

First, you understand, don't you, that the concept of "conviction" was passed fifty miles ago as what happened is that Chad Brown has ADMITTED to the offenses described in the consent decree? Whether or not the facts alleged are true has already been settled.

Your reference to room and board and wage packages have nothing to do with the issues. If Chad Brown is going to have employees, he has to comply with federal and state law like any other employer, which means (among other things) paying employees a minimum wage and paying overtime. He has admitted he did not do that, to a large number of employees. If he is going to hire employees under the H-2B program, he is going to have to comply with the terms of that program, like any other employer. As the complaint alleged regarding the H-2B failures: He collected payment from employees for visa costs, which should have been paid by him. He failed to reimburse employees' transportation and subsistence costs for travel from their home countries. He misrepresented to employees the place of employment and job terms and conditions, such as the availability of free housing. And last but not least, he failed to disclose required information in a language understood by the employees.

Your narrative suggests that what you think was offered to employees "doesn't seem criminal." Chad clearly knew what he was doing was wrong as he engaged in a pattern (again, acknowledged in the consent decree) of widespread falsification of time records. Further, as the complaint alleged, Brown had already been cited in 2010 by New York State for his failure to maintain adequate time records, so he could hardly plead ignorance of his obligations under federal and state law regarding record-keeping.

The facts that Brown has acknowledged tell a sorry tale of a greedy employer taking advantage of low-skilled, vulnerable workers and doing everything he could to conceal his wrongdoing. He should get no quarter from anyone on this board.