If you were one of the two women found that day, or if you recognize yourself in this story, you are not what was done to you
You are reading this in a quiet room, probably alone, and something in the news this week made the back of your neck go hot. Maybe it was the photograph of the hotel on Papermill Drive. Maybe it was the description of an undercover agent posing as a fourteen-year-old. Maybe it was the name of the man the Tennessee Bureau of Investigation says was a former youth baseball director. Maybe it was simply the word “Knoxville” — your Knoxville, the same interstate exit where you used to check in for work you did not choose, in a room that was not yours, with money you never saw.
You are not “in the life.” The life was something that happened to you. The difference matters in law as much as it matters in your body. Federal civil rights law, Tennessee statute, and decades of human-trafficking case law all start from the same premise: a person cannot consent to being sold, and a buyer cannot use the word “consent” as a shield when the seller was force, fraud, coercion, or — for a minor — was never a transaction at all.
If a Knoxville hotel rented the room where it happened, a youth organization provided the cover, an online platform brokered the connection, or a chain of any of those three let a known pattern continue, you may have a civil case against every one of them — separate from any criminal prosecution. The federal Trafficking Victims Protection Act (TVPRA), and Tennessee’s own civil-trafficking statute T.C.A. § 39-13-314, give you that door. The clock is long. The proof is fragile. The call to our firm is free, confidential, and Spanish-speaking (Hablamos Español). The number is below.
This page is written for the person reading it at 2 a.m. with shaking hands. We are the same firm that picks up.
What happened in West Knoxville on April 21, 2026 — and why the civil case is different from the criminal case
On April 21, 2026, the Tennessee Bureau of Investigation’s Human Trafficking Unit and the Knoxville Police Department closed a two-day undercover operation that began with decoy advertisements on websites known to broker commercial sex. The primary focus, the TBI has stated, was identifying individuals seeking to engage in sex acts with minors. Officers responded to a hotel on Papermill Drive in West Knoxville around 1 p.m. on April 21 and began making arrests.
Eight people were charged. The court records identified in news reporting include Adrian Gonzales Ramirez, 42, of Knoxville, charged with one count of solicitation of a minor — patronizing prostitution (victim under 15); Christopher Steven Goodrich, 44, of Knoxville, charged with one count of patronizing prostitution and one count of solicitation of a minor — patronizing prostitution (victim under 15), and described in news reporting as a former director for Perfect Game Knoxville, a youth baseball organization; Charles Ed. Boles Jr., 48, of Rockwood; Raymond Alexander, 72, of Knoxville; Lingli Zheng, 47, of San Gabriel, California, charged additionally with bribery of a public servant; and Hongtao Li, 47, of Arcadia, California, charged with one count of prostitution. The TBI has said investigators are following up on hundreds of contacts made during the operation, and that two individuals identified as potential trafficking victims were offered services through Willowbend Farms.
None of the criminal charges above are our practice. We are not the defense bar. We represent trafficking survivors, and the people who love them, in civil cases under federal and Tennessee law — separate from any prosecution, and with different rules about who can be named as a defendant, what damages are available, and how long you have to file.
The criminal case belongs to the Knox County District Attorney General. The civil case belongs to you. Both can move at the same time. They are built from different evidence, and the civil case is built to put real money in your hands and accountability on the institutions that profited.
Three doors into a Tennessee civil case for a trafficking survivor
A Knoxville trafficking survivor today has three independent civil causes of action, and we file the ones the facts of your case support — often all three at once.
Door one: federal TVPRA, 18 U.S.C. § 1595. The Trafficking Victims Protection Reauthorization Act gives an individual who is a victim of a violation of Chapter 77 of Title 18 a federal civil action against the perpetrator — and, just as important for our purposes, against whoever knowingly benefits, or attempts or conspires to benefit, financially or by receiving anything of value from participation in a venture which that person knew or should have known has engaged in an act in violation of this chapter. That second clause is the one that reaches a Knoxville hotel whose front desk kept handing the same man a key, a youth organization whose logo sat on the perpetrator’s jacket, and an online platform that collected a fee for the ad. The remedy is damages and reasonable attorneys’ fees. (Federal source: 18 U.S.C. § 1595(a).)
Door two: Tennessee’s own civil trafficking action, T.C.A. § 39-13-314. Tennessee gives victims of trafficking a state-law civil action against the people who recruited, enticed, harbored, or transported them — and against those who financially benefited from the venture. This is the statute that gives a Tennessee jury the authority to award treble damages and attorneys’ fees. Trebling is the leverage that turns a hotel negligent-security case into a verdict the hotel actually has to reckon with. The discovery rule applies; the clock depends on when you knew, or reasonably should have known, that you were trafficked and by whom.
Door three: ordinary Tennessee tort law against the premises and product defendants. Negligent security on the hotel, negligent hiring/supervision/retention against the youth organization, negligent entrustment, negligent training, ordinary premises liability, fraud, and intentional infliction of emotional distress. The civil-trafficking statutes ride on top of these, but the common-law claims do the heavy lifting for a single survivor against a single defendant.
We file all three when the facts support it, because each survives attacks the others do not. A hotel can argue “we didn’t know and the criminal statute requires knowledge” — but a jury in Tennessee does not need knowledge to find ordinary negligence. A youth organization can argue “we only loaned him a title” — but civil conspiracy and ratification theories reach his actions to the organization that held him out.
Why a hotel on Papermill Drive is on the hook even if a guest is the one who hurt you
A hotel’s defense team will say, within the first week: “We are the victim here, too. We rented a room. We had no idea.” That defense is wrong, and it fails the moment you line up three specific things the law already makes the hotel prove it had in place, or did not.
First, what the front desk actually did. A hotel that has the same guest checking in every week, paying cash, refusing housekeeping, and bringing different young companions to the same room is a hotel that has accumulated a body of observable fact. Federal training material for hotel staff, hospitality-industry standards, and the case law reaching the same conclusion in other jurisdictions all converge on the same list of red flags: cash-only stays, refusal to provide identification, third-party payment for a guest who never appears at the desk, “do not disturb” signs that last for days, excessive requests for towels and linens, heavy short-stay foot traffic through one room, a companion who never appears at the front desk, and prior staff reports of suspicious activity. A Knoxville hotel that ignored all of it, when its industry tells it exactly what to look for, did not “have no idea” — it had a pattern it chose not to connect.
Second, what the cameras actually recorded. Hotel surveillance in this corridor of West Knoxville, in 2026, is essentially universal. The camera is on at the elevator bank, the parking lot, the lobby, and often every floor’s hallway. That footage lives on a server the hotel can save, and it is typically overwritten on a rolling cycle that can be as short as days to weeks. If the hotel’s own cameras caught the same man with the same room night after night, the cameras are the proof. The cameras are also the proof the hotel will try to lose. We send the preservation letter the day you call.
Third, what the police and 911 records say. The Knoxville Police Department is on Papermill Drive regularly. A hotel on that corridor has had calls for service. That history is public record under Tennessee’s open-records law, and it is the spine of the foreseeability case: a property owner cannot plead surprise at a danger the public had already flagged.
“An individual who is a victim of a violation of this chapter may bring a civil action against the perpetrator (or whoever knowingly benefits, or attempts or conspires to benefit, financially or by receiving anything of value from participation in a venture which that person knew or should have known has engaged in an act in violation of this chapter)… and may recover damages and reasonable attorneys’ fees.”
— 18 U.S.C. § 1595(a) (Trafficking Victims Protection Reauthorization Act civil remedy)
A jury in Knoxville does not need to find that the hotel manager woke up one morning and decided to enable sex trafficking. A jury needs to find that a reasonable hotel, presented with the red flags the industry itself trains for, would have stopped the pattern. That is ordinary negligence, it is also the federal beneficiary-liability standard, and it is what T.C.A. § 39-13-314 was written to reach.
Why Perfect Game and any youth-sports organization is on the hook for a director it held out as its own
The news reporting describes Christopher Steven Goodrich as a former director for Perfect Game Knoxville, a youth baseball organization. A youth-sports organization is not shielded from civil liability for the acts of an adult it held out to parents and children as its representative, just because it later stops calling him a director. Tennessee law on negligent hiring, supervision, and retention is straightforward: if the organization knew, or should have known, that this adult presented a risk to minors in its programs, and it held him out as a director anyway, it is responsible for what he did to children while wearing the organization’s name. The organization’s brand is the operative fact. Parents put their children in front of people wearing that brand.
The deeper theory is civil conspiracy and ratification. The organization can say “he was acting outside the scope of his duties” — and we will respond with the prior complaints it received about him, the training it did not give him on the federal mandated-reporting clock (more on that below), the red flags it ignored in its own background-check process, and the parents it never warned when the organization became aware of a problem. In Tennessee, civil conspiracy is a recognized tort, and it reaches a network of actors who agreed — formally or by clear conduct — to a course of action that produced the harm.
We also pursue a separate set of claims against any online platform that brokered the contact that brought the survivor to the hotel. In 2018, Congress stripped the broad statutory immunity of Section 230 of the Communications Decency Act for a narrow but powerful category of claims: civil actions brought under 18 U.S.C. § 1595 where the conduct underlying the claim is a sex-trafficking violation under 18 U.S.C. § 1591. (See 47 U.S.C. § 230(e)(5).) The bar on Section 230 immunity is narrow, but for a trafficking survivor it is real, and the platform’s role in connecting buyer, seller, and venue can be the missing piece of the money trail.
The single most dangerous phrase in any trafficking case: “you consented”
Every defense in a sex-trafficking case begins with the word “consent.” Tennessee juries in civil cases will hear the same playbook:
- “She was an adult, she chose this work.”
- “The hotel was the victim of the sting, not the trafficker.”
- “Our client is a youth-sports organization, not a criminal enterprise.”
- “The criminal case hasn’t even gone to trial; how can you sue civilly?”
- “We need to see the survivor’s medical records, mental-health records, school records, immigration records, and social-media history before we can talk.”
We have heard every version of this script. We answer each one with what the law actually says.
On consent. Under federal law, a commercial sex act is a “severe form of trafficking” when it is induced by force, fraud, or coercion — and when the person is under 18, the consent question is gone. The TBI’s own charging documents reflect that: the counts filed include “solicitation of a minor — patronizing prostitution (victim under 15).” For an adult survivor, we document the coercion in its real form — economic coercion, psychological coercion, drug dependency, threat of harm to family, the everyday machinery of control that does not look like kidnapping to a stranger but functions as captivity to the person living it. Tennessee law recognizes this. Federal law recognizes this. The case law recognizes this. A defense that calls it “consent” is asking the jury to ignore how trafficking actually works.
On timing. The criminal case and the civil case run on different clocks and different rules of evidence. Tennessee civil procedure does not require a criminal conviction as a prerequisite to a civil action. We do, however, benefit from any plea, conviction, or sentencing — and we coordinate with the District Attorney’s office when the survivor consents. A survivor’s privacy is the priority, and a victim-advocate or Willowbend Farms case manager is in the room before any witness-prep conversation happens.
On records discovery. Defense lawyers will demand the survivor’s medical, mental-health, and social-media history. We will not let that demand become a fishing expedition. Tennessee’s rules on the discoverability of mental-health records in tort cases, the federal sensitivity around sexual-assault records, and our own protective orders limit what the defense gets. We will turn over what the law requires. We will not let the defense turn a civil case into a humiliation of the survivor.
On the Tennessee treble-damages lever. T.C.A. § 39-13-314 gives a Knoxville jury the power to award treble damages and attorneys’ fees. That is not a punitive-damages instruction — it is the state legislature’s specific answer to the question, “how do we make the institutions that profit from trafficking actually pay for the harm?” The treble multiplier is the reason a civil case against a Knoxville hotel or a Perfect Game organization is worth filing, even when the underlying injury is severe but the available insurance is thin.
The evidence clock: what is being saved, and what is being lost right now
This is the most important section of this page for someone reading it today. The proof of a trafficking case dies on multiple clocks running at the same time, and most of those clocks are already ticking.
The hotel’s own records. The surveillance footage from the Papermill Drive hotel is on a server, and on a rolling-overwrite cycle that is typically days to weeks. Key-card access logs, property-management-system data, folio and payment records, housekeeping logs, and incident reports are all in the hotel’s control and all subject to the hotel’s retention policy, which is not designed to preserve evidence for a future lawsuit. We send a litigation-hold letter within 48 hours of being retained. The letter names the cameras, the key-card system, the PMS, the housekeeping records, the cash-payment logs, and the staff incident reports by name. If the hotel overwrites the footage after that letter, the jury gets to assume the footage showed what the survivor says it showed.
The Knoxville Police Department and TBI files. The TBI’s investigative file is the spine of the criminal case and a centerpiece of the civil case. The complaint records, the call-for-service history at the hotel, the 911 audio, the witness statements, and the body-worn camera footage are public records, but they are also subject to the agency’s retention schedule. We request everything early. We also coordinate, with the survivor’s consent, to understand what the criminal investigation has uncovered.
The booking platform and the ad data. Decoy advertisements on websites known to broker commercial sex were the entry point for the operation. The platforms that hosted those ads keep their own records, and federal preservation rules for online platforms (including the FOSTA amendments to 18 U.S.C. § 2421A) extend specific obligations to retain evidence once the platform becomes aware of a federal investigation. The platform that brokered the connection in your case may still have the messages, the payment records, and the metadata showing who posted and who responded.
The youth organization’s internal records. Perfect Game Knoxville and any affiliated organization keep files on its directors, coaches, and program staff. Background-check files, prior complaint files, training records on federal mandatory reporting of suspected child abuse (see below), and internal email and text threads are the spine of the negligent-supervision case against the organization. Those records are the easiest to lose to routine turnover and the hardest to reconstruct. We want them preserved before someone “cleans out the office.”
The survivor’s own records. The hospital and clinic records, the mental-health treatment records, the SANE exam, the photographs of injuries taken in the days after each incident, the contemporaneous texts to family or friends, and the very first outcry to anyone — these are the records that prove the case. We work with Willowbend Farms and the survivor’s chosen advocate to gather them in a trauma-informed way, on the survivor’s timeline, never on the defense’s.
The federal mandatory-reporting clock. Federal law, 18 U.S.C. § 2258A, requires any electronic-service provider to report apparent child sexual abuse material to the National Center for Missing & Exploited Children (NCMEC) CyberTipline as soon as reasonably possible, and to preserve related data for one year. The REPORT Act of 2024 (Pub. L. 118-59) expanded the covered offenses to include child sex trafficking and enticement. A platform or youth organization that had actual knowledge of suspected trafficking of a minor and failed to report is in violation of federal law. The civil case reaches that violation directly.
The point of all of this is simple. If you are reading this and you are one of the survivors, or you are the family of one, the next thirty days are more important than the next three years. The cameras are overwriting. The key-card data is rolling. The booking platform’s retention is policy, not law. The TBI’s case file is growing, but the public-record window is finite. The hotel’s defense team is already gathering its own evidence. The single most important step is the call to our firm, today, so that the preservation letter goes out while the proof still exists.
Contact us through this page to start that conversation.
What your case is actually worth, in dollars, in Knoxville
We do not promise outcomes. We do not promise headline numbers. We do not publish “verdict” figures and imply they are yours. (As we state in every engagement: Past results depend on the facts of each case and do not guarantee future outcomes.)
What we can tell you is the shape of the range, drawn from the categories of damages a Knoxville civil-trafficking case can recover and the specific multipliers the law allows.
Compensatory damages are the out-of-pocket and the human losses: medical and mental-health treatment (past and future), lost wages and lost earning capacity, the cost of recovery and rehabilitation, relocation expenses for a survivor who needs to leave the area, and the human losses a Tennessee jury is allowed to put a number on — pain, suffering, emotional distress, loss of enjoyment of life, loss of consortium where the law allows it. In a minor-survivor case, life-care planning, future lost earnings projected over a worklife, and the cost of decades of therapy form the spine.
Treble damages under T.C.A. § 39-13-314. Tennessee’s civil-trafficking statute permits the jury to multiply compensatory damages by three. This is not a punitive-damages instruction; it is a statutory multiplier that turns a hotel that rented a room for $80 a night into a defendant facing three times the harm it caused.
Attorneys’ fees and costs. Both the federal TVPRA (18 U.S.C. § 1595(a)) and Tennessee’s civil-trafficking statute provide for the recovery of reasonable attorneys’ fees. We are paid on contingency; the case does not cost you anything out of pocket, and if we do not win, you owe us nothing.
The realistic case-value range. A civil-trafficking case involving a minor and a high-profile institutional defendant (a hotel chain, a youth-sports organization, an online platform) is not a routine premises case. Based on the categories of recovery, the treble multiplier, and the fee-shifting provisions, the realistic case-value range for a single-survivor case against a single major institutional defendant starts in the low six figures, and can reach into the multi-millions depending on the injury, the duration of the trafficking, the number of defendants, and the trebling. For the higher end, you need more than one defendant, a documented pattern at the venue, and a survivor whose life has been materially and quantifiably derailed by what happened. We do not assert a specific number for your case on this page. We will tell you, in a confidential consultation, what the realistic range looks like in your specific facts.
The defense playbook: what the insurance adjusters and defense lawyers will do, and how we counter each move
The institutions on the other side of a Knoxville trafficking case have insurance. They have adjusters. They have a defense playbook that is, by now, almost formulaic. We name the plays and we name the counter for each.
Play one: “We are the victim of the sting too.” This is the hotel’s first line. The answer is that the hotel is the venue, not the trafficker — and the civil case is about the hotel’s own conduct, not the criminal defendant’s. The jury is asked to compare a survivor’s life to a hotel’s room-revenue line, and that comparison is the case.
Play two: “We didn’t know.” This is the constructive-knowledge defense. The answer is the red-flag pattern and the case law that says what a reasonable hotel should have seen. Federal training material, hospitality-industry standards, and the FBI’s own indicators of human trafficking all converge on the same list. A hotel that ignored all of them, when its industry tells it exactly what to look for, did not “not know” — it had a pattern it chose not to connect.
Play three: “We’ll need her full mental-health and medical history.” This is the fishing-expedition demand. The answer is the protective order and the trauma-informed discovery protocol. Tennessee’s rules on the discoverability of mental-health records, and the federal sensitivity around sexual-assault records, limit what the defense gets. We protect the survivor’s dignity and we do not let the defense turn the civil case into a second assault.
Play four: “We’ll make this go away if you sign this.” This is the quick-NDA offer. The answer is that you do not sign anything without a lawyer reviewing it. The defense knows a survivor with no income, in immediate need of treatment, and afraid of being publicly identified is vulnerable to a fast offer. We slow it down. We negotiate from a position of knowing what the case is actually worth.
Play five: “The criminal case will sort it out.” The answer is that the criminal case and the civil case are different cases. A criminal conviction helps the civil case. A criminal acquittal does not end the civil case. The standards are different, the remedies are different, and the burden of proof is different.
Play six: “We have no insurance for this.” The answer is that every hotel, every youth organization, and every online platform carries commercial general liability coverage, and the question is whether the policy excludes the conduct. The exclusion fight is its own war, and we run it in court, not in a back room.
Play seven: “Statute of limitations.” More on that in the next section, but the short answer is: the federal TVPRA clock is ten years from the act (or ten years after the survivor turns eighteen if a minor), and T.C.A. § 39-13-314 has its own discovery-rule provisions. The defense is hoping you wait.
How long you have: the statute of limitations, in plain language
There are two clocks running at once, and you need to know both.
The federal TVPRA clock, 18 U.S.C. § 1595(c). The federal civil action must be commenced not later than the later of (1) ten years after the cause of action arose, or (2) ten years after the victim reaches eighteen years of age, if the victim was a minor at the time of the alleged offense. For a survivor who was a minor when the trafficking occurred, the ten-year clock does not even start until the survivor turns eighteen. The federal clock is long. The proof is shorter.
The Tennessee clock, T.C.A. § 39-13-314. Tennessee’s civil-trafficking statute provides its own statute of limitations and incorporates a discovery rule, meaning the clock starts when the survivor knew, or reasonably should have known, that they were trafficked and by whom. The interaction of the state and federal clocks is one of the things we map in your consultation, because the right answer depends on the specific facts.
The point is not the math. The point is the urgency. The longer you wait, the more of the proof dies. The cameras overwrite. The key-card data rolls. The booking platform’s retention policy moves on. The TBI’s case file grows, but the public-records window is finite. If you are reading this and the TBI sting in April 2026 was about what happened to you, or to someone you love, the call you make this week will determine what the case looks like in court.
What the survivor’s first conversation with us actually sounds like
We know the call is the hardest part. Here is what it sounds like, in the order it happens.
You call 1-888-ATTY-911 or reach us through our contact page. A live person answers, twenty-four hours a day, seven days a week. There is no answering service. We are not a referral service. We are the firm.
A member of our intake team listens, takes down what you are willing to share, and schedules a confidential consultation with the right attorney on our team. We do not push. We do not ask for your name twice. We do not require you to tell the whole story on the first call.
The consultation is free. It is confidential. It can happen in English or in Spanish, in person, on the phone, or over video. We explain the three doors into a Tennessee civil case (federal TVPRA, state § 39-13-314, and ordinary tort). We explain the discovery rule. We explain treble damages. We explain contingency. We explain the survivor’s right to privacy and the limits of defense discovery. We explain the evidence-preservation plan and we start it the same day.
If you decide to move forward, we file a case. We do not get paid unless we recover for you. No fee unless we win. That is the entire financial conversation.
Who we are: the people who will be in the room with you
Our firm was built on the premise that the people who get hurt in a Knoxville or a Houston or a Beaumont wreck are entitled to the same quality of representation as the people who caused the wreck. We bring the same standard to a trafficking case.
Ralph Manginello has been a Texas-licensed trial lawyer since 1998, more than twenty-seven years, and is admitted to the U.S. District Court for the Southern District of Texas. He earned his J.D. from South Texas College of Law Houston in 1998 and his B.A. in Journalism and Public Relations from the University of Texas at Austin. Before law school he was a journalist, and the discipline of checking what a fact is before you print it is a habit that has not left him. He is a member of the State Bar of Texas, the Houston Bar Association, the Harris County Criminal Lawyers Association, the Texas Trial Lawyers Association, the National Association of Criminal Defense Lawyers, and the Pro Bono College of the State Bar of Texas. He has spent more than two decades trying cases to juries in the parts of the country where corporations, insurers, and government agencies meet the people they have hurt.
Lupe Peña is a Texas-licensed trial lawyer with more than thirteen years in courtrooms, including federal court. He earned his J.D. from South Texas College of Law Houston in 2012 and his B.B.A. in International Business from Saint Mary’s University in San Antonio. Before joining our firm, Lupe spent years on the other side of the table as a defense attorney for a national insurance company, in the rooms where claims were priced, where the software ran the value, and where the strategy was to delay and devalue. He now uses that knowledge on your side. He is fluent in Spanish, conducts full client consultations in Spanish without an interpreter, and is the reason we say “Hablamos Español” and mean it.
We work Tennessee cases. Where Tennessee bar admission is required, we work with local Tennessee counsel and appear pro hac vice, the same way we work every other state. We do not invent a Tennessee bar admission and we do not pretend to have a Tennessee office. We bring the resource and the record, and we bring the people you will actually be talking to.
What we cannot do, and what that is worth knowing
We cannot make a criminal case go away for the people who were arrested on Papermill Drive. That is the District Attorney’s call, and the TBI’s.
We cannot guarantee that the survivor’s identity will remain out of the news. News reporting on the April 2026 sting has already named some of the men arrested. If you are one of the two women already identified by the TBI and referred to Willowbend Farms, you are already in the case file the TBI controls. We can, however, work to keep your name out of the public record in any civil filing, and we can seek protective orders that limit what the defense is allowed to do with your identity and your records.
We cannot undo what happened. We cannot promise you a verdict. We cannot promise a number. We can, and we do, build a civil case that puts real money in your hands, real accountability on the institutions that profited, and a real record of what happened to you, in a court of law, with the protections the law gives you.
How the page closes
We started this page with the person reading it alone at 2 a.m. We are going to end it the same way.
You are not what was done to you. The life was something that happened to you, not something you are. The law — both federal and Tennessee — has been catching up to that truth for two decades, and the doors it has built are open.
We are the firm that picks up the phone. We are the firm that sends the preservation letter the day you call. We are the firm that builds the case on the proof, not on the promise. We are the firm that takes Tennessee cases, work with Tennessee counsel where required, and walks into a Knoxville courtroom as if we have always been in it.
The number is 1-888-ATTY-911. The consultation is free. No fee unless we win. And when you are ready, in English or in Spanish, we are ready too.
Hablamos Español.
Past results depend on the facts of each case and do not guarantee future outcomes. The information on this page is general legal information about civil remedies available to trafficking survivors under federal and Tennessee law, not legal advice for your specific case. Tennessee is not the firm’s home state of admission; we work Tennessee cases with local counsel where required. Calling our firm does not create an attorney-client relationship; that relationship is created only by a signed engagement letter after a confidential consultation.
Frequently Asked Questions
I am one of the two women already identified by the TBI and referred to Willowbend Farms. What do I do first?
The single most important step is a free, confidential consultation with our firm so we can send the litigation-hold letter the same day. The hold letter names the hotel’s cameras, key-card system, property-management-system data, and housekeeping logs; the booking platform’s records; the youth organization’s internal files; the TBI’s open investigative file; and your own treatment and outcry records, and it tells every one of them to preserve. Once the hold is in place, we sit down with you, with your advocate or case manager from Willowbend Farms if you want, and we walk you through the three civil doors. There is no cost and no obligation. The number is 1-888-ATTY-911.
I was an adult at the time, not a minor. Do I still have a case?
Yes. The federal TVPRA, 18 U.S.C. § 1595, protects victims of “a commercial sex act induced by force, fraud, or coercion” — and the definition of coercion in the case law is broad enough to capture economic coercion, psychological coercion, drug dependency, and the everyday machinery of control. Tennessee’s T.C.A. § 39-13-314 also covers adult trafficking victims. The criminal case in West Knoxville included charges that named victims under fifteen, but adult survivors have their own path to civil recovery. We will tell you, in the consultation, whether your facts fit the statute.
How long do I have to file a civil case?
Two clocks, and the right one for you depends on the facts. The federal TVPRA clock is ten years from the cause of action, or ten years after the survivor turns eighteen if a minor at the time of the offense (18 U.S.C. § 1595(c)). The Tennessee clock, T.C.A. § 39-13-314, has its own discovery rule that starts the clock when the survivor knew, or reasonably should have known, that they were trafficked and by whom. The exact answer in your case depends on the dates, the defendants, and the state of the evidence. We will map both clocks in your consultation. The short version is: the federal clock is long, and the proof is shorter. Waiting costs the case.
Can I sue the hotel even if the criminal case has not yet gone to trial?
Yes. Tennessee civil procedure does not require a criminal conviction as a prerequisite to a civil action. The criminal case and the civil case run on different rules of evidence and different burdens of proof. A criminal conviction, when it comes, will help the civil case. A criminal acquittal does not end the civil case. We coordinate with the Knox County District Attorney’s office, with the survivor’s consent, so that the civil case does not interfere with the prosecution.
Can I sue Perfect Game or the youth organization if Goodrich was only described as a “former” director?
Yes. The “former” label does not insulate the organization. Tennessee law on negligent hiring, supervision, and retention looks at what the organization held the person out to be, what it knew, and what it did or did not do. If Perfect Game Knoxville held Goodrich out as a director to parents and children, the organization is responsible for what he did while wearing that title, even if the title has since been withdrawn. We also pursue civil conspiracy and ratification theories that reach the organization for the acts of a person it empowered and then disavowed.
Can I sue the online platform that hosted the ad or the message?
Often, yes. The 2018 FOSTA amendments to Section 230 of the Communications Decency Act stripped the broad statutory immunity of those platforms for the narrow but important category of claims brought under 18 U.S.C. § 1595 where the conduct underlying the claim is a sex-trafficking violation under 18 U.S.C. § 1591. The bar on immunity is narrow, but for a trafficking survivor it is real. We have to plead the trafficking predicate precisely and we have to connect the platform’s specific role in the venture, but the door is open.
Will the defense try to get my medical and mental-health records?
Yes. The defense will demand your medical history, your mental-health treatment history, your school records, your social-media history, and, where applicable, your immigration history. Tennessee’s rules on the discoverability of mental-health records in tort cases, the federal sensitivity around sexual-assault records, and our own protective orders limit what the defense gets. We will turn over what the law requires. We will not let the defense turn the civil case into a second assault. We work with trauma-informed discovery protocols and we put the survivor’s dignity at the center of the process.
What if I cannot afford a lawyer?
You do not need to afford one. Our firm works these cases on contingency. We are paid a percentage of what we recover, and if we do not recover, you owe us nothing. The federal TVPRA and the Tennessee civil-trafficking statute both provide for the recovery of reasonable attorneys’ fees, which means a successful case shifts the cost of our work to the defendant. The consultation is free, the case is no-fee-unless-we-win, and the consultation happens in English or in Spanish.
Will the criminal verdict help my civil case?
A criminal conviction helps the civil case. A guilty plea helps the civil case. Even a criminal acquittal does not end the civil case. We will tell you, as the criminal case moves, what is admissible and what is not, and we will coordinate strategy with the District Attorney’s office with your consent.
What if I already signed something — an NDA, a release, a settlement?
Do not sign anything else. The first thing we do in the consultation is review any document you have already signed. Some NDAs and releases are enforceable; some are not. Some were signed by a person who was not in a position to give informed consent, under conditions that amounted to coercion. We will tell you what you signed, what it covered, and what it left open. Do not delay the call because of a document. The document is exactly the kind of thing that requires a lawyer’s eye.
Can I remain anonymous?
We can, and routinely do, file civil cases under pseudonyms (e.g., “Jane Doe” or “John Doe”) where the court allows it. The level of anonymity the court will permit depends on the defendants’ due-process rights and the public’s interest in open proceedings. We fight for as much protection as the law allows, and we work with the survivor’s advocate and case manager throughout.
What if I am not ready to file today?
Then we send the preservation letter today, on your behalf, and we wait. The preservation letter is the first move, and it does not require you to commit to a case. The letter buys you the time the proof needs. When you are ready, the proof will still be there.