Helen is sole proprietor of small home health care agency. A former employee sued for unpaid wages under the Fair Labor Standards Act and New York Labor Law, claiming that she worked 24 hours per day, 7 days a week. She alleged that her daily pay rate was below the minimum wage when you took into account all the hours she worked and that she never received overtime pay. Helen believed that the aide was at liberty while the client was sleeping and during breaks during the day, so that her daily pay rate was legally sufficient (because the law requires that wages be paid only for actual hours worked). Helen had hired a private lawyer but he withdrew from the representation when she became unable to pay his fees. NYLAG secured limited scope pro bono counsel to defend her at her deposition and to take the plaintiff’s deposition. NYLAG then assisted Helen in opposing the plaintiff’s motion for summary judgment.