Question 4. For three consecutive peach-harvesting seasons, Moses Michael Levi Brown worked as a farm laborer for Georgia Packing ("GeoPack"). After quitting his job in the middle of the third season, Brown sued his former employers. GeoPack later moved to compel arbitration under agreements signed by Brown after he traveled to the United States and started harvesting peaches. GeoPack Packing Company is a farm labor contractor for Ariana Brothers, a Georgia-based grower of vegetables. In 2018, Brown resided in Corozal, Belize, supporting his wife and their parents, by providing housing and medical care for his wife, his mother, his now-deceased stepfather, and his diabetic mother-in-law. That year, he learned about an opportunity to work for GeoPack in the United States. A job at GeoPack paid up to five times as much as Brown earned in Belize. In 2019, GeoPack accepted Brown's application and helped him obtain an H-2A temporary agricultural worker visa. GeoPack then transported Brown to Coffee County, Georgia, to start the job. GeoPack held orientations for incoming employees. For Brown, the orientation occurred the day after he arrived after a forty-hour bus ride from Belize to the United States and he had begun harvesting peaches in the fields. The orientation took place at the end of the workday, at around 4 p.m., in a hotel parking lot. At the orientation, some 150 workers were asked to sign employment paperwork. To facilitate the signing of the paperwork, GeoPack representatives directed employees to form lines, where they stood-in at least one case for 40 minutes-and waited to sign the packages. Once at the front of the line, a GeoPack representative told each employee where to sign while flipping through the pages. A GeoPack employee then transported Brown to housing provided by CalPak. Brown believed that he could not work for any other employer, had no other place to live in the United States, and no other means of transportation back to Belize. Representatives urged employees to hurry so that others could have a chance to sign. The employment package included an arbitration agreement. The agreement required employees to resolve all disputes with GeoPack by arbitration. Although the agreement was written in Spanish, a language taught in Brown's secondary schooling education, Brown spoke Yucatec Maya at home growing up and with his family. Brown signed the arbitration agreement without reading it. GeoPack representatives didn't explain the contents of the arbitration agreement to Brown, didn't give him a copy of the agreement, and didn't tell him he could consult an attorney before signing it. On the other hand, Brown didn't ask for a copy of the agreement, attorney consultation, or time to read the agreement. Brown argues that GeoPack officials told him that he had to sign the agreement to keep working for the company, a claim GeoPack officials have repeatedly denied. Brown completed the 2019 season and traveled back to Belize on GeoPack-funded transportation. For the 2020 season, Brown again harvested peaches for GeoPack in Monterey County, Georgia. He also signed an arbitration agreement for the 2020 season. But Brown didn't finish the 2020 season. He quit GeoPack mid-season and returned to Belize on his own. Brown has come to you to sue GeoPack on behalf of himself and other similarly situated workers. In response, GeoPack has responded it will compel arbitration under the two arbitration agreements. Evaluate the enforceability of the Arbitration Agreements. 0136.50