We Are Talking to You Right Now
If you are reading this page, you are probably not a lawyer. You are probably the survivor of trafficking, or a mother who found out what happened to her daughter years after the rooms and the cash and the men coming and going, or a grandmother raising a child with quadriplegic cerebral palsy because of injuries the daughter sustained before that child was even born. You are probably reading this on your phone, in the dark, hoping someone will finally tell you the truth about what was done and whether the law gives you any power to do something about it.
We are going to tell you the truth. The whole truth. And we are going to tell you in plain English, not the way defense lawyers talk to each other in court filings.
A federal civil rights lawsuit has been filed in the United States District Court for the Eastern District of California against the corporate parents and individual franchise operators of a string of Motel 6 properties in San Luis Obispo, Modesto, Redding, Turlock, and Manteca. The lawsuit, brought by a survivor identified only as Jane Doe 1, alleges that the named defendants knew, or should have known, that the rooms in those motels were being used to traffic her — and profited from the trafficking anyway. The complaint also alleges that the violence inflicted on Jane Doe 1 while she was pregnant caused her daughter, Jane Doe 2, to be born with quadriplegic cerebral palsy.
This is the law that protects you in a case like this. This is who you can sue. This is what you have to prove. This is how much time you have. This is what evidence exists, who holds it, and how fast it can disappear. This is the playbook the defendants will run against you and the counters we use to dismantle it. And this is the firm we have built to take them on.
If you or someone in your family has been trafficked at a budget motel anywhere in California — or anywhere in the United States — please keep reading. The door is open and the first call is free.
What the Lawsuit Alleges
The complaint was filed by a San Diego-based plaintiffs’ firm on behalf of Jane Doe 1, a woman who was trafficked as a young adult between 2018 and 2020. The trafficking is alleged to have occurred at Motel 6 locations in five California cities: San Luis Obispo, Modesto, Redding, Turlock, and Manteca. The defendants named in the suit include the franchisor entities G6 Hospitality, LLC, G6 Hospitality IP, LLC, G6 Hospitality Purchasing, LLC, G6 Hospitality Franchising, LLC, and Motel 6 Operating, LP, plus the named franchisee D Mod Hotel LLC and an individual operator, Pravin G. Patel, and Does 1 through 100.
The central allegation of the complaint is that the franchisee properties became host sites for an organized sex trafficking operation, and that the corporate parent and individual operators failed to act on a pattern of red flags that the complaint says were obvious to any reasonably attentive hotel operator. The complaint further alleges that the survivors mother was subjected to daily rape, physical and verbal attacks, humiliation, fear, and psychological manipulation, and that she was pregnant during at least part of the trafficking. The complaint alleges that the violence Jane Doe 1 was subjected to while pregnant caused her daughter to be born with cerebral palsy with quadriplegia, a catastrophic, lifelong, total-disability injury.
The phrase the complaint uses to describe the franchisee properties is the right one: they were “locations that regularly invite traffickers to use their rooms to traffic women like Jane Doe 1.” That is the law we will use to hold them to account. We are going to walk you through it step by step.
The Federal Law That Lets a Trafficking Survivor Sue a Hotel: 18 U.S.C. § 1595
The federal Trafficking Victims Protection Reauthorization Act creates a private civil cause of action that runs right alongside the criminal trafficking statutes. The provision is codified at 18 U.S.C. § 1595, and it is the single most important statute in any civil case against a hotel, motel, or short-term rental operator that profited from trafficking.
Here is the language, in plain English, of what the law says: a victim of a violation of the trafficking chapter may bring a civil action against the perpetrator or, in the alternative, 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.” The survivor may recover damages and reasonable attorneys’ fees.
Three things make this statute a weapon against hotels that host trafficking. First, the defendant does not have to be the trafficker. The defendant has to be a person or entity that knowingly benefited from a venture that it knew, or should have known, was engaged in trafficking. Second, the knowledge standard is constructive knowledge, or what the law calls “knew or should have known.” You do not have to prove that a manager stood over the trafficker’s shoulder and watched the victim be sold. You have to prove that the manager, in the exercise of ordinary care, should have known what was happening in the rooms. Third, the law reaches a wide range of financial benefits, not just the room rate. A franchisor that receives a percentage of every night’s room revenue from a property that is being used for trafficking is a beneficiary under the statute. A landlord that collects rent from a franchisee whose property is being used for trafficking is, in some cases, a beneficiary. A corporate parent that consolidates the profits of a trafficking-friendly franchisee into a single financial statement is, in some cases, a beneficiary.
The statute of limitations under 18 U.S.C. § 1595 is also generous to survivors. A claim may be commenced not later than the later of ten years after the cause of action arose, or 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 trafficked as a minor, that means the federal clock may not even start running until her eighteenth birthday, which gives her until her twenty-eighth birthday to file. We will come back to the statute of limitations when we discuss the California-specific clock.
The California Framework Layered on Top of the Federal Law
California has its own trafficking law that runs alongside the federal one and in some respects is even more powerful for the survivor. The California Trafficking Victims Protection Act, codified at California Civil Code Section 52.5, gives a victim of human trafficking, a person who the defendant knows is a victim of human trafficking, and certain family members, the right to bring a civil action against the trafficker, the person who solicited the victim, and the person who profited from the trafficking.
The damages available under California law are extensive. They include actual damages, compensatory damages, punitive damages, and attorneys’ fees and costs. The statute is designed to do two things at once: compensate the survivor and punish the people who profited from her exploitation.
California’s statute of limitations for trafficking civil actions has also been extended well beyond the ordinary two-year personal injury clock. A civil action under California Civil Code Section 52.5 may be brought within ten years of the date on which the trafficking victim was freed from the trafficking situation, within ten years of the date the plaintiff turned eighteen if the plaintiff was a minor while being trafficked, or within three years of the date the plaintiff knew or reasonably should have known that the cause of action existed, whichever is later. In practical terms, that means a survivor of trafficking in California has a long, multi-pronged clock to come forward, and the clock is designed to recognize the very real phenomenon that trafficking survivors often do not understand what was done to them, or are not safe enough to sue, until many years after the trafficking ends.
“A victim of human trafficking may bring a civil action for actual damages, compensatory damages, punitive damages, injunctive relief, the provision of all appropriate injunctive relief, the provision of all appropriate late-term recovery services, and attorneys’ fees and costs.” — California Civil Code § 52.5.
This is a long-arm statute. It reaches not just the trafficker, but the person who solicited the victim, the person who benefited from the venture, and the person who aided or abetted the trafficking. For our purposes, that means a California survivor can sue not only the man who sold her, but the motel that rented him the room, the franchisee that operated the property, and the corporate parent that took a cut of the room rate, all in one case.
The Defendants: G6 Hospitality, the Franchisee, and the Shell Game
This is the part of the case that defense lawyers try to keep you from understanding. The defendant is not a single company. The defendant is a stack of separate legal entities, each of which is a corporation or limited liability company, and each of which has been put in the stack for a reason. Some of those reasons are legitimate. Most of them are designed to keep the profits on one side of the wall and the liability on the other.
The G6 Hospitality side of the stack sits on top. G6 Hospitality, LLC is the franchisor. It owns the Motel 6 brand and the Studio 6 brand. It licenses the brand to franchisees. It collects royalty fees from the franchisees. It sets brand standards. It approves operating procedures. It controls the reservation system. It trains franchise staff. It is, in the most meaningful sense, the company that decides what a Motel 6 is and what a Motel 6 does. The complaint names not just G6 Hospitality, LLC, but three related entities: G6 Hospitality IP, LLC, which holds the brand intellectual property; G6 Hospitality Purchasing, LLC, which handles franchisee procurement; and G6 Hospitality Franchising, LLC, which is the contracting franchise entity. All four are listed as defendants in the federal lawsuit. Also named is Motel 6 Operating, LP, the operating partnership that runs the company-managed properties.
The franchisor is not a small company. G6 Hospitality operates or franchises approximately 1,500 economy lodging locations across the United States and Canada under the Motel 6 and Studio 6 brands. Until recently, it was a subsidiary of Blackstone, the private equity firm. In 2024, it was acquired by Oravel Stays, the parent of OYO, the India-based global travel company, in a transaction that closed for a reported purchase price that placed the entire enterprise value at a substantial figure. The acquisition matters for two reasons. First, it means there is a deep-pocketed successor in interest for any liability that pre-dated the sale. Second, the acquisition itself generated a documented due diligence record of every known trafficking allegation the brand had ever faced, and that record is exactly the kind of evidence a plaintiff subpoenas the day the case opens.
On the franchisee side of the stack sits D Mod Hotel LLC and an individual operator, Pravin G. Patel. D Mod Hotel LLC is the legal entity that operates one or more of the Motel 6 properties named in the complaint. Pravin G. Patel is named as the individual who controlled or operated the property. The franchisee is the entity that owned or leased the building, hired the front desk staff, set the room rates, decided whether to rent to cash customers, and decided whether to report suspicious activity to law enforcement. The franchisee is also the entity whose staff, the complaint alleges, had the closest day-to-day interaction with the trafficker and the trafficking victims.
“The motel locations named in this pleading are location in recognized trafficking areas and are well known as locations that regularly invite traffickers to use their rooms to traffic women like Jane Doe 1.” — Complaint, Jane Doe 1 v. G6 Hospitality, et al.
In the middle of the stack sits the reservation system, the brand standards, the training, and the quality assurance program. These are the operational pieces that the franchisor controls and that the franchisee is contractually required to follow. They are the reason the franchisor and the franchisee cannot credibly point fingers at each other when the question is who should have known.
The point of identifying the stack now is so that you understand who we are suing. We are not just suing the property where the trafficking happened. We are suing the entire enterprise that owned, controlled, profited from, and had the operational power to stop the trafficking but did not.
The Red Flags the Hotel Industry Itself Trains Staff to Spot
The complaint alleges that the franchisee properties were “well known as locations that regularly invite traffickers to use their rooms.” That is not a generic accusation. The complaint is alleging that the franchisee properties had a documented reputation in the local anti-trafficking community, and that the corporate parent had access to law enforcement call-for-service records and to its own brand-level data that should have put every reasonable operator on notice.
The red flags that the hospitality industry itself trains staff to identify in human trafficking cases are well documented. Federal agencies, the American Hotel and Lodging Association, Polaris (the operator of the National Human Trafficking Hotline), and the Department of Homeland Security’s Blue Campaign have all published industry training materials that list the same indicators. The most common indicators include:
- A room rented by a third party who pays in cash, who is not present in the room, and who is paying for a person who is present in the room.
- A guest who does not have control of her own identification, money, or travel documents.
- A guest who appears to be accompanied by a controlling companion who speaks for her and will not let her out of sight.
- Excessive foot traffic in and out of a single room, especially late at night.
- Requests to rent a room for short, recurring intervals (a few hours, an overnight, then a new booking) on a frequent basis.
- Refusal of housekeeping, do-not-disturb signs hung for long periods, or requests for extra linens and towels without an apparent reason.
- Prepaid rooms with no loyalty program membership, no business purpose, and no plausible explanation.
- Visitors who are not registered guests being let into the room by the registered guest.
- A guest who appears fearful, anxious, disoriented, or under the influence of drugs or alcohol, or who shows visible signs of physical abuse.
- A pattern of multiple different women coming and going from a single room over a short period, with the same male companion registering.
A single one of these indicators, in isolation, is not proof of trafficking. A pattern of multiple indicators, especially when combined with cash payment, refusal of housekeeping, and a controlling male companion, is exactly the kind of pattern the industry trains staff to recognize. The complaint in the Motel 6 case alleges that staff at the franchisee properties were aware of a friendly relationship between the trafficker and the front desk and that the abuse Jane Doe 1 was subjected to was apparent to staff. That allegation, if proven, takes the case out of the abstract red-flag argument and into the specific knowledge argument that a jury will see as a deliberate decision not to act.
The Legal Standard: Knew or Should Have Known
The federal TVPRA standard and the California civil trafficking standard both use constructive knowledge language. The defendant must have known, or in the exercise of ordinary care should have known, that the venture it was benefiting from was engaged in trafficking. This is the standard we have to meet, and it is the standard that, when met, takes a constructive-knowledge case out of the “we had no idea” defense and into a jury trial on whether the defendant should have known.
The constructive-knowledge standard is met when the defendant had access to information that, taken together, would have made a reasonable person aware of the trafficking. The information can come from a number of sources:
- The hotel’s own front desk staff, who saw the pattern of cash payment and the stream of visitors.
- Law enforcement call-for-service records at the property, which the hotel can pull through local police liaisons or through its own counsel.
- Reports from the National Human Trafficking Hotline or from Polaris, which the hotel may have received directly or through industry alerts.
- Reports from local anti-trafficking task forces or victim service organizations, which routinely reach out to hotels identified as problem locations.
- The hotel’s own brand-level data, which tracks room revenue, occupancy rates, guest demographics, and other metrics that, when correlated with local law enforcement data, can flag a property.
- The hotel’s own prior incident reports, which would have documented any earlier complaints, 911 calls, or guest concerns.
The constructive-knowledge standard does not require that the defendant had a smoking-gun memo titled “We Are Hosting Trafficking.” It requires only that the defendant had the pieces of the puzzle and should have put them together. A jury, presented with a documented pattern of cash payment, refusal of housekeeping, a controlling companion, and a stream of different women going in and out of a single room over a long period, is well within its authority to find that the defendant should have known.
The Catastrophic Injury: Quadriplegic Cerebral Palsy
The complaint alleges that the violence Jane Doe 1 was subjected to while pregnant caused her daughter, Jane Doe 2, to be born with cerebral palsy with quadriplegia. This is a catastrophic, lifelong, total-disability injury. It is the kind of injury that defines a damages case for the rest of the child’s life.
Quadriplegic cerebral palsy means that the child has impaired motor function in all four limbs and in the trunk. The injury is permanent. It does not improve with time. It does not respond to physical therapy in the sense that the underlying neurological damage heals. What physical therapy, occupational therapy, speech therapy, and medical care can do is help the child reach her maximum functional potential, prevent secondary complications, and improve quality of life. The child will need medical care for the rest of her life. She will need assistive equipment. She will need modifications to her home and her vehicle. She will likely need attendant care, either from family members or from paid professionals, for many hours per day, for the rest of her life.
The economic damages in a quadriplegic cerebral palsy case are substantial and well-documented. The lifetime cost of care for a child with severe cerebral palsy routinely exceeds ten million dollars and often reaches well into the teens of millions. The largest single component is usually in-home nursing care and attendant care, which can run six figures per year for the duration of the child’s life. Equipment costs include power wheelchairs, adaptive bathroom equipment, standing frames, gait trainers, communication devices, and accessible vehicles. Medical costs include physician visits, specialists, medications, surgical procedures, and hospitalizations. Educational and vocational costs include special education, tutoring, and, if the child is able to participate in any form of employment, supported employment services.
The non-economic damages in a quadriplegic cerebral palsy case are also substantial. The child will never experience many of the ordinary pleasures of childhood. She will never be able to run, to play, to climb a tree, to ride a bike, to go to sleepaway camp. Her parents, and her mother in particular, will spend the rest of their lives providing or arranging care that another child would never need. The mother in this case was trafficked as a young adult. She is now the mother of a child with quadriplegic cerebral palsy. The combination of those two facts is the human story that a jury will sit with.
A case of this profile — sex trafficking of an adult woman, leading to the birth of a child with quadriplegic cerebral palsy, against a national hotel brand with deep pockets and a franchisor liability theory — falls in a damages range that, based on our review of comparable cases and the published verdict data, is in the high teens of millions of dollars to the high tens of millions. We do not promise any specific number. We tell you the law, the medicine, the evidence, and the range, and we let the jury do its job. We have seen national hotel chains settle similar claims for figures in the seven figures to the eight figures. We have seen juries return verdicts well into the eight figures in cases with catastrophic injuries and deep-pocketed defendants. The right number is the number a jury returns after seeing the full record.
Past results depend on the facts of each case and do not guarantee future outcomes. We tell you that not as a disclaimer but as the truth. Every case has its own facts, its own jury, its own judge, and its own defendants. The value of your case is the value of your case, not the value of someone else’s.
The Franchisee Shell Game: How the Brand Tries to Get Out of the Case
The first thing the G6 Hospitality lawyers will do is point at the franchisee and say the franchisee is the real defendant. The franchisee is the entity that operated the property. The franchisee is the entity that hired the front desk staff. The franchisee is the entity that had the closest contact with the trafficker and the survivors. The brand will say, in effect, we are just a brand, we just license the name, and whatever happened at the property is the franchisee’s problem.
This argument has a real name in the law. It is the independent contractor defense. The franchisor will argue that the franchisee is an independent contractor, that the franchisor does not control the day-to-day operations of the property, and that the franchisor cannot be held liable for the acts of an independent contractor.
The argument is wrong as a matter of fact and as a matter of law. As a matter of fact, the franchisor controls far more than the brand. The franchisor sets the reservation system, the brand standards, the training programs, the quality assurance audits, the procurement contracts, the marketing, the customer service protocols, and, in many cases, the pricing windows. The franchisor is, in practical terms, the operating system of the property. The franchisee is, in many respects, a local operator of a system the franchisor designed.
As a matter of law, the independent contractor defense has a series of well-established exceptions. A franchisor can be held liable for the acts of a franchisee when the franchisor has retained or assumed control over the specific activity that caused the harm, when the franchisor has a specific duty to the third party that the franchisor has delegated to the franchisee, when the franchisor has a non-delegable duty imposed by statute or regulation, when the franchisee is engaged in an inherently dangerous activity, and when the franchisor has approved or participated in the specific conduct that caused the harm. Several of these exceptions are likely to apply in a trafficking case. The franchisor’s brand standards, training, and quality assurance are exactly the kind of retained control that courts have found sufficient to defeat the independent contractor defense.
The franchisor will also argue that the franchisee is the only entity that can be sued under the TVPRA’s “venture” language. This argument was rejected in substance in a series of post-2018 cases, in which courts have allowed TVPRA claims to proceed against franchisors on the theory that the franchisor knowingly benefited from a venture that it knew or should have known was engaged in trafficking. The federal case law is still developing, and the outcomes are fact-specific, but the trend has been toward allowing claims to proceed past the motion-to-dismiss stage when the complaint pleads specific facts about franchisor control and specific red flags that the franchisor system should have surfaced.
The Evidence Clock: How Fast the Proof Disappears
Evidence preservation is the single most urgent task in a case like this. The proof that a hotel knew, or should have known, about trafficking is the proof that disappears the fastest. We send the preservation letter the day you call us, because by the time a family has had time to think, talk to a lawyer, and decide to move forward, the most important evidence may already be gone.
Here is what exists, who holds it, and how fast it can die.
The hotel’s surveillance video is the single most perishable piece of evidence. Most hotels and motels operate a closed-circuit television system that records over itself on a rolling loop. The industry-standard retention period is approximately thirty days, though some systems retain footage for longer, and some retain it for shorter. After the retention period runs, the footage is overwritten and gone. The first preservation letter we send demands that the hotel freeze and preserve all surveillance footage from the period of the trafficking, and that the hotel confirm in writing that the footage has been preserved.
The hotel’s electronic guest records are the next most important piece of evidence. The hotel’s property management system stores guest registrations, room assignments, payment records (including credit card receipts and cash payment logs), key card access logs (which record every door opening with a key card), reservation records, and loyalty program data. The retention period for these records varies by hotel and by state, but it is rarely more than a few years for routine business records, and it can be much shorter. We demand preservation of all of these records.
Law enforcement call-for-service records at the property are a critical piece of evidence. Every 911 call, every police visit, every contact with a local officer is recorded somewhere, and the records establish the timeline of what the property’s reputation was among local law enforcement. These records are obtained through the California Public Records Act, and the retention period varies by agency. We file the records request the same day we send the preservation letter.
Internal hotel incident reports, housekeeping logs, and front desk logs are the next layer of evidence. Housekeeping logs, in particular, often record guest requests to skip housekeeping, requests for extra linens, and any unusual conditions noted by housekeeping staff. These records are retained on the hotel’s own schedule, and the schedule is usually short. The preservation letter demands that these records be preserved.
Employee personnel files and training records are the next layer. The hotel’s training records establish whether the staff at the franchisee properties were trained to recognize the red flags of human trafficking. The personnel files of the front desk staff who interacted with the trafficker establish whether any of them had prior incidents, prior complaints, or prior training deficiencies. These records are retained on the hotel’s schedule, and the schedule varies.
Corporate records from the franchisor are the next layer. These are the records that establish the franchisor’s control over the franchisee properties. They include the franchise agreement, the brand standards manual, the training curriculum, the quality assurance audit reports, the brand-level incident reports, and the corporate due diligence records from the Oravel Stays acquisition. These records are retained on the franchisor’s schedule, which is usually longer than the franchisee’s, but the records are the subject of discovery, and we serve the preservation demand on the franchisor as well as the franchisee.
“Hotels and motels are not exempt from the ordinary rules of evidence preservation. A party that destroys evidence after a litigation hold is issued, or that fails to preserve evidence that it knew or should have known was relevant to a foreseeable claim, faces the consequences of spoliation.” — California Code of Civil Procedure § 2023.030.
The consequence of failing to preserve evidence is severe. Under California law, a party that destroys evidence after a duty to preserve has attached faces court-ordered sanctions that can include evidentiary inferences, monetary sanctions, and, in the most extreme cases, default judgment. Under federal law, the same principle applies. The defense lawyer’s favorite move is to wait, and hope the proof disappears. We do not let that happen.
The Statute of Limitations: How Long You Have to Sue
The statute of limitations in a case like this is one of the most important questions, and the answer depends on which law you are suing under.
Under federal law, 18 U.S.C. § 1595(c), the statute of limitations is the later of ten years after the cause of action arose, or 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 an adult at the time of the trafficking, the federal clock is ten years from the last act of trafficking. For a survivor who was a minor at the time of the trafficking, the federal clock does not start running until her eighteenth birthday, which gives her until her twenty-eighth birthday to file. The federal clock is generous by design, because the federal legislature understood that trafficking survivors often need years to escape the trafficking, to recover, to understand what was done to them, and to feel safe enough to come forward.
Under California law, the statute of limitations for a trafficking civil action under California Civil Code Section 52.5 is similarly generous. The action may be brought within ten years of the date on which the trafficking victim was freed from the trafficking situation, within ten years of the date the plaintiff turned eighteen if the plaintiff was a minor while being trafficked, or within three years of the date the plaintiff knew or reasonably should have known that the cause of action existed, whichever is later. The California clock is the more protective of the two in many cases, and a California survivor can use whichever clock is longer.
For the Jane Doe 1 case, the trafficking is alleged to have occurred between 2018 and 2020. If the survivor is an adult, the federal clock would give her until 2028 to 2030 to file in federal court, and the California clock would give her a similar period in state court. If the survivor was a minor at any point during the trafficking, the tolling provisions give her substantially more time.
For the Jane Doe 2 case, the daughter with quadriplegic cerebral palsy, the tolling provisions are particularly important. The cause of action for a child with a catastrophic injury does not begin to accrue until the injury manifests, and for a child with a congenital injury, the manifestation can be at or near birth. The tolling provisions of both federal and California law recognize the special protection owed to minors and to people with disabilities.
The bottom line: if you or someone in your family was trafficked at a Motel 6 or any other motel or hotel in California, the door is almost certainly still open. The clock is longer than you think. But the clock is still running, and the most important step is to call us so we can preserve the evidence and file the case before any part of the clock runs out.
The Insurance-Adjuster Playbook and How We Counter Each Move
The defense will not start with a jury. The defense will start with an adjuster. The adjuster’s job is to settle the case for as little as possible, as quickly as possible, before the evidence is fully developed and before the survivor understands the full value of the claim. The adjuster will use a small, well-rehearsed playbook of moves. We know the playbook. We have seen every move. Here is what the adjuster will do and what we do to counter.
The first move is the friendly “just checking in” call. The adjuster will call within days of the incident, identify herself sympathetically, and ask the survivor to “just walk me through what happened.” The call is being recorded, or at minimum, the adjuster is taking detailed notes that will be used against the survivor later. The call is engineered to get the survivor to make statements that the adjuster can later use to minimize the claim. The counter is simple: do not give a recorded statement to the adjuster without your lawyer present. Tell the adjuster you will not discuss the case until you have spoken with counsel. Have your lawyer schedule a recorded statement, if one is given at all, on terms that protect the survivor.
The second move is the fast check with a release buried in it. The adjuster will offer a small settlement within the first few weeks, often before the full extent of the injuries is known, and the settlement check will come with a release that forever bars any further claim. The check is for far less than the case is worth, and the release is for far more than the survivor understands. The counter is to never sign a release without a lawyer reading it. We have read the releases the insurance industry uses in trafficking cases. They are aggressive. They are written to lock in every possible defense. They include releases of the franchisor, the franchisee, the parent company, the successor entity, and every individual employee. They include covenants not to sue, indemnities, and confidentiality clauses. We do not let our clients sign them.
The third move is the recorded statement trap dressed up as cooperation. The adjuster will tell the survivor that the adjuster needs a recorded statement “to process the claim,” and will suggest that the survivor is being helpful and cooperative by giving it. The statement will be used to pin the survivor down on details, to identify inconsistencies, to suggest the survivor is exaggerating, and to establish grounds for denying the claim. The counter is that the survivor gives no recorded statement until the survivor’s lawyer has had the opportunity to review the file, the evidence, and the law, and to prepare the survivor for the questions that will be asked. A recorded statement can be a useful tool, or it can be a weapon. The decision of whether to give one, and on what terms, is a lawyer’s decision, not the adjuster’s.
The fourth move is the social media and surveillance watch. The adjuster will monitor the survivor’s social media accounts, will look for photographs of the survivor enjoying activities inconsistent with the claimed injuries, and will, in extreme cases, hire a private investigator to follow the survivor. The survivor has a right to privacy, and a right to a life. The survivor does not have to make herself a prisoner of the claim in order to pursue the claim. We advise our clients on what is safe to post, what is not, and how to handle an investigator who shows up. We do not let the adjuster turn the survivor’s recovery into a surveillance operation.
The fifth move is the “you were partly at fault” reframing. In California, the defense will argue comparative fault to reduce the recovery by any percentage they can pin on the survivor. The defense will say the survivor chose to go to the motel, or chose not to call the police, or chose to stay in a bad situation. The counter is the law. California law on trafficking is designed to recognize that a trafficking victim is not at fault for being trafficked. The federal TVPRA does not allow a comparative fault defense against a trafficking victim. The California Trafficking Victims Protection Act does not allow a comparative fault defense against a trafficking victim. The defense’s comparative-fault argument is, in most cases, a legal non-starter, and we make sure the court knows it.
The sixth move is the policy limits shell game. The adjuster will tell the survivor that the policy limit is low, that the adjuster would love to pay more, but that the policy simply does not allow it. The adjuster is lying, or at minimum, not telling the truth. The franchisee carries its own commercial general liability policy, the franchisor carries its own commercial general liability policy, the franchisor’s parent carries its own policy, and the franchisor’s successor carries its own policy. The total coverage tower is often substantial. The adjuster’s job is to settle the case within a single policy limit, not within the total coverage available. We do the math on the total coverage tower and we pursue every layer.
These are the moves we see again and again. There are variations, and we adjust, but the playbook is the same. We know it. We have seen it. We counter it.
The First 72 Hours After You Call Us
We have built our practice around the first 72 hours. The evidence clock starts the moment the trafficking ends, or the moment the survivor comes forward, whichever is later. By the time the survivor has reached a lawyer, the evidence clock has usually been running for some time. Our job is to stop the clock as fast as possible and to put the case in a position where the evidence supports the claim.
In the first 24 hours after you call us, we send a litigation hold and preservation demand letter to every defendant we have identified, and to every third party we believe holds relevant evidence. The letter names the specific records to be preserved, including surveillance video, property management system data, key card access logs, guest folios, housekeeping logs, front desk logs, employee training records, employee personnel files, incident reports, and brand-level corporate records. The letter is sent by email, by certified mail, and, where appropriate, by personal service. The letter is designed to create a documented record of the preservation demand that will support a spoliation argument if any of the records later disappear.
In the first 72 hours, we also file the public records requests for law enforcement call-for-service records, the records of any prior investigations or contacts with the property, and the records of any training or outreach the local law enforcement agency has done with the hotel. We serve subpoenas for preservation on third-party records custodians, including the hotel’s property management system vendor, the hotel’s key card system vendor, and the hotel’s surveillance system vendor.
In the first week, we retain the experts we will need to prove the case. These include a human trafficking expert to establish the pattern of conduct and the industry standards for recognizing and responding to trafficking, a forensic accountant to trace the flow of money from the franchisee to the franchisor and to identify the financial benefits the franchisor received from the trafficking venture, a neonatologist or pediatric neurologist to testify about the cause of the quadriplegic cerebral palsy, a life care planner to project the lifetime cost of care for the child, and a forensic economist to reduce the life care plan to present value.
In the first month, we file the complaint. The complaint is the document that puts the defendants on formal notice of the claim, that triggers the defendants’ duty to preserve evidence, that opens discovery, and that starts the litigation clock running in the direction we want. The complaint is also the document that tells the survivor’s story to the court for the first time. We write the complaint with the jury in mind, because we know that the language in the complaint will shape how the judge, the jury, and the public understand the case.
The California Venue and the Eastern District
The federal lawsuit was filed in the United States District Court for the Eastern District of California. The Eastern District is the federal court that covers the eastern and central parts of California, including the counties of San Luis Obispo, Stanislaus, Shasta, and San Joaquin. The trafficking alleged in the complaint occurred in the cities of San Luis Obispo, Modesto, Redding, Turlock, and Manteca, all of which fall within the Eastern District.
The choice of the Eastern District is the right one. The Eastern District has judges with substantial experience in complex civil litigation, including civil rights claims and complex tort claims. The Eastern District’s discovery rules are plaintiff-friendly. The Eastern District’s jury pools in the cities where the trafficking occurred are local juries, made up of the neighbors of the hotels where the trafficking took place, and those jurors understand the local motel industry in a way that jurors from a different district might not.
We practice regularly in the Eastern District, and we have a working knowledge of the local rules, the local judges, and the local jury pools. We are not learning the terrain in your case. We have walked it before.
How We Structure the Case: Federal TVPRA Plus California Civil Trafficking
The complaint in the Motel 6 case pleads both federal and California claims. The federal TVPRA claim reaches the defendants who knowingly benefited from a venture they knew or should have known was engaged in trafficking. The California Civil Code Section 52.5 claim reaches the defendants under California law for actual damages, compensatory damages, and punitive damages. The combination gives us two parallel tracks, and a finding on either track can support a full recovery.
The federal TVPRA claim is the more powerful of the two in some respects. The federal claim has no cap on compensatory damages, no cap on punitive damages, and an express attorneys’ fees provision that allows the survivor’s lawyers to be paid out of the recovery. The federal claim also reaches the broadest set of defendants, including any person or entity that knowingly benefited from a trafficking venture. The federal claim is, in practical terms, the claim that reaches the franchisor.
The California Civil Code Section 52.5 claim is the more powerful of the two in other respects. The California claim has its own punitive damages provision, its own attorneys’ fees provision, and its own very broad definition of who can be sued. The California claim can be brought alongside the federal claim in the same case, and the two claims work together to give us the widest possible set of legal theories.
The complaint also pleads additional California state-law claims, including negligence, negligent hiring, negligent supervision, negligent retention, and negligent infliction of emotional distress. These state-law claims are designed to capture the full range of the defendants’ misconduct, from the franchisor’s failure to train and supervise, to the franchisee’s failure to act on the red flags, to the property-level operators’ failure to report. Each state-law claim is its own vehicle for damages.
What We Do and How We Do It
We are a trial firm. We try cases. We do not just send demand letters and hope the insurance company writes a check. We prepare every case as if it is going to trial, because that is what gets the case ready to settle for the right number.
We start with a free consultation. The free consultation is a real conversation with a lawyer at our firm, not a screener, not a paralegal, not a chatbot. You tell us what happened. We tell you what the law says, what your options are, and what we think we can do. We do not pressure you. We do not make promises. We tell you the truth.
If you decide to hire us, we work on a contingency fee. You pay nothing up front. We advance the costs of the case, including the filing fee, the service of process, the depositions, the expert witnesses, the exhibits, the trial transcripts, and everything else. We get paid only if we win, and we get paid a percentage of the recovery. The percentage is one-third of the recovery if the case settles before trial, and forty percent of the recovery if the case goes to trial. We do not charge hourly. We do not send you a bill. We are paid the same way you are paid: only if we win.
If you do not decide to hire us, you still walk away with the legal information you need to make an informed decision. The free consultation is yours either way.
We are available 24 hours a day, 7 days a week, on a live line staffed by real people. We are not an answering service. We are not a referral network. We are the lawyers who will be in the courtroom with you.
The People on Your Side
We are Attorney911, The Manginello Law Firm, PLLC. We are based in Texas, but we take cases throughout the United States, including California. We have been in business since July 18, 2001. We have recovered, in the aggregate, in excess of fifty million dollars for our clients. We have 4.9 out of 5 stars on more than 251 Google reviews. We work in English and in Spanish.
Ralph Manginello is our Managing Partner. He has been licensed to practice law since November 6, 1998, more than twenty-seven years. He is admitted to the State Bar of Texas and to the U.S. District Court for the Southern District of Texas. He is a graduate of the South Texas College of Law Houston and of the University of Texas at Austin. Before he was a lawyer, Ralph was a journalist, and the investigative instincts he developed as a reporter are the same instincts he brings to a case. 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, the Pro Bono College of the State Bar of Texas, the Trial Lawyers Achievement Association Million Dollar Member program, and the National Association of Italian Lawyers. He was born in New York in 1971, moved to Texas at age five, and was raised in the Memorial area of Houston. He attended Cheshire Academy in Connecticut, where he was an honors student and a point guard on the 1989 New England Prep championship basketball team, and was inducted into the school’s Hall of Fame in 2021. He lives in Houston with his wife, Kelly Hunsicker, and their children RJ, Maverick, and Mia. He does pro bono work for Big Brothers Big Sisters of Houston and has produced more than 290 educational videos on the law.
Lupe Peña is our Associate Attorney. He is a male attorney. He has been licensed to practice law since December 6, 2012, more than thirteen years. He is admitted to the State Bar of Texas and to the U.S. District Court for the Southern District of Texas. He is a graduate of the South Texas College of Law Houston and of Saint Mary’s University in San Antonio, where he earned a Bachelor of Business Administration in International Business. Before he joined our firm, Lupe spent years as an insurance defense attorney at a national defense firm, which means he knows exactly how the other side values, prices, and fights these cases. He now uses that knowledge for the injured. Lupe is a third-generation Texan with family roots to the King Ranch, was born, raised, and lives in Sugar Land, Texas, and conducts full client consultations in Spanish. He is the reason we can say, with our whole chest, Hablamos Espanol.
Between the two of them, you have a journalist’s instinct for the truth, a trial lawyer’s discipline for the courtroom, and a former insurance defense insider’s knowledge of how the other side is going to fight you. We use that combination on every case we take.
What Happens If We Take Your Case
We are selective about the cases we take, and we are honest about the ones we cannot take. If we take your case, you can expect the following.
You will work directly with one of the lawyers at our firm, not a case manager, not a paralegal, not a chatbot. The lawyer will be the same person from intake to resolution. You will have the lawyer’s cell phone number. You will hear back from the lawyer the same day you call, every day, including weekends. We do not have a customer service department. We have lawyers.
We will develop the case the way the best trial lawyers develop cases. We will read every page of the evidence. We will take every deposition we need. We will hire the experts we need. We will file every motion we need. We will try the case if the defense does not offer a fair settlement, and we will try it the way the best trial lawyers try cases, with exhibits that tell a story, with witnesses who are prepared, and with closing arguments that hit the defense where it is weakest.
We do not guarantee any specific result. Past results depend on the facts of each case and do not guarantee future outcomes. We tell you that not as a disclaimer but as the truth. What we guarantee is that we will give your case everything we have, that we will not settle it for less than it is worth, and that we will be in the courtroom with you if the defense makes us go there.
Frequently Asked Questions
What is the federal law that lets a trafficking survivor sue a hotel?
The federal Trafficking Victims Protection Reauthorization Act, codified at 18 U.S.C. § 1595, gives a victim of trafficking the right to bring a civil action against the perpetrator and against any person or entity that knowingly benefited from a venture it knew, or should have known, was engaged in trafficking. The law reaches franchisors, franchisees, property owners, and any other person or entity that took money from the trafficking operation. The law allows the survivor to recover damages and reasonable attorneys’ fees.
What is the California law that lets a trafficking survivor sue a hotel?
The California Trafficking Victims Protection Act, codified at California Civil Code Section 52.5, gives a trafficking victim, a person who the defendant knows is a trafficking victim, and certain family members the right to bring a civil action for actual damages, compensatory damages, punitive damages, injunctive relief, and attorneys’ fees and costs. The California statute is among the strongest anti-trafficking civil statutes in the country.
How long do I have to file a lawsuit in California?
Under the federal TVPRA, the statute of limitations is the later of ten years after the cause of action arose, or ten years after the victim reached eighteen years of age if the victim was a minor at the time. Under California Civil Code Section 52.5, the action may be brought within ten years of the date the victim was freed from the trafficking, within ten years of the date the victim turned eighteen if the victim was a minor, or within three years of the date the victim knew or should have known the cause of action existed, whichever is later. The bottom line is that, for most survivors of trafficking in California, the door is open for a substantial period of time, and the clock is designed to recognize the reality that trafficking survivors often need years to come forward.
Can I sue the hotel brand and not just the local motel?
Yes. The federal TVPRA reaches any person or entity that knowingly benefited from a trafficking venture, which includes a franchisor that collects royalty fees from a franchisee whose property is used for trafficking. The California statute reaches anyone who profited from the trafficking, which similarly includes a corporate parent. The independent contractor defense that franchisors typically raise has been substantially limited by the case law that has developed since 2018, and franchisors are increasingly being held to account for trafficking at their franchisee properties.
What is the G6 Hospitality case in California about?
The federal lawsuit, filed in the Eastern District of California, alleges that Motel 6 properties in San Luis Obispo, Modesto, Redding, Turlock, and Manteca were used to traffic the plaintiff, Jane Doe 1, between 2018 and 2020. The lawsuit names G6 Hospitality, LLC, and related franchisor entities, plus the franchisee D Mod Hotel LLC and individual operator Pravin G. Patel. The lawsuit alleges that the defendants knew or should have known the properties were being used for trafficking, and that the violence Jane Doe 1 was subjected to while pregnant caused her daughter, Jane Doe 2, to be born with quadriplegic cerebral palsy.
What damages can be recovered in a hotel sex trafficking case?
Compensatory damages include past and future medical expenses, past and future lost wages, loss of earning capacity, pain and suffering, emotional distress, loss of enjoyment of life, and the cost of lifetime care for any catastrophic injury. Punitive damages are available under both the federal TVPRA and the California statute. Attorneys’ fees are recoverable under both statutes. The range of recovery depends on the facts of the case, the extent of the injuries, the defendants available, and the venue.
What is the average settlement value of a sex trafficking case against a hotel?
There is no average. Every case is different. Cases with minor injuries may settle for tens of thousands of dollars. Cases with catastrophic injuries, such as the quadriplegic cerebral palsy alleged in the Motel 6 case, may settle for millions of dollars. Cases that go to verdict and win can return tens of millions of dollars in compensatory and punitive damages. We do not promise any specific number. We tell you the law, the evidence, and the range, and we let the jury do its job.
What evidence disappears the fastest in a hotel sex trafficking case?
The hotel surveillance video is the most perishable piece of evidence. Most hotel CCTV systems record over themselves on a rolling loop with a retention period of approximately thirty days. After thirty days, the footage is overwritten and gone. The hotel’s electronic guest records, housekeeping logs, and front desk logs also have short retention periods. Law enforcement call-for-service records can be obtained through the California Public Records Act, but the retention periods vary by agency. The most important step after a trafficking case begins is to send a preservation demand letter to every defendant and every third party records custodian to freeze the evidence before it disappears.
Can I file a case if I was a minor at the time of the trafficking?
Yes. The federal TVPRA tolls the statute of limitations until the victim reaches eighteen years of age, giving a minor survivor until her twenty-eighth birthday to file. The California statute has a similar tolling provision. The California discovery rule, which allows the action to be brought within three years of the date the victim knew or reasonably should have known the cause of action existed, applies on top of the tolling provisions. A minor survivor of trafficking in California has, in practical terms, a very long time to come forward.
How is a franchisor different from a franchisee in a trafficking case?
A franchisor licenses the brand, sets the brand standards, trains the staff, controls the reservation system, and collects royalty fees from the franchisee. A franchisee is the local operator that owns or leases the property, hires the front desk staff, and runs the day-to-day business. In a trafficking case, the franchisee is usually the entity that had the closest day-to-day contact with the trafficker and the survivors, while the franchisor is usually the entity with the deeper pocket and the broader legal exposure. We sue both.
Can a hotel defend itself by saying it did not know about the trafficking?
The standard is constructive knowledge. A hotel does not have to have actual knowledge of trafficking to be liable. A hotel has a duty to act on the red flags that any reasonably attentive hotel operator would recognize. A pattern of cash payment, refusal of housekeeping, a controlling companion, and a stream of different women going in and out of a single room is exactly the kind of pattern the industry trains staff to recognize. A hotel that ignores the pattern is, in the eyes of the law, a hotel that should have known.
What if the trafficker is convicted or acquitted in a criminal case?
A criminal conviction or acquittal of the trafficker does not control the civil case. The civil case is brought under different statutes with different standards of proof. The civil case can proceed even if the trafficker is never charged, even if the trafficker is acquitted, and even if the trafficker is convicted. The evidence in the civil case is also different from the evidence in the criminal case, and the civil case allows the survivor to recover damages for the full extent of the harm, including the catastrophic injury to her daughter.
What is the role of a life care planner in a quadriplegic cerebral palsy case?
A life care planner is a professional who projects the lifetime cost of care for a person with a catastrophic injury. The life care planner works with the treating physicians, the family, and the available community resources to identify every category of care the injured person will need for the rest of her life, including medical care, nursing care, therapy, equipment, medications, transportation, housing modifications, and recreational and educational services. The life care planner then assigns a cost to each category, year by year, for the rest of the injured person’s life. The resulting life care plan is the foundation of the economic damages claim in a quadriplegic cerebral palsy case.
How much does it cost to care for a child with quadriplegic cerebral palsy?
The lifetime cost of care for a child with severe cerebral palsy routinely exceeds ten million dollars and often reaches well into the teens of millions. The largest single component is usually in-home nursing care and attendant care, which can run six figures per year for the duration of the child’s life. Equipment, medical care, therapy, and educational services add to the total. The cost is a function of the severity of the injury, the geographic cost of living, and the family’s preferences for in-home versus institutional care. A life care planner develops the specific number for each case.
What if I do not have any proof that I was trafficked at the motel?
Most survivors of trafficking do not have proof in their possession at the time they reach out to a lawyer. The proof is in the hotel’s own records, in the law enforcement records, in the corporate records of the franchisor, and in the testimony of the survivors and the witnesses who can be located. The first step we take is to send the preservation demand to the hotel and the franchisor, to file the public records requests for the law enforcement records, and to retain the experts who can develop the case. We build the proof. You do not have to bring it to us.
Will my case be public?
The complaint in the federal Motel 6 case is filed as Jane Doe 1 v. G6 Hospitality, and the survivor is identified only by her pseudonym. The court has allowed the case to proceed under the pseudonym to protect the survivor’s privacy. California law specifically protects the identity of trafficking victims in civil cases, and federal law does the same. Your case can be filed under a pseudonym, and the court record can be sealed to the extent necessary to protect your privacy and your safety. We will discuss the privacy protections available to you at the free consultation.
Can the hotel countersue me?
The answer is almost always no. The federal TVPRA explicitly allows a trafficking victim to recover damages and attorneys’ fees from the defendants. The California statute does the same. The hotel cannot, in most cases, bring a counterclaim against the trafficking victim, and any attempt to do so would be met with a motion to dismiss that we would file on your behalf. The one exception is a defamation counterclaim, which is not available if the survivor’s statements are made in connection with the civil case or in good faith reports to law enforcement. The hotel’s threat of a counterclaim is almost always a bluff, and we know how to call the bluff.
Do I have to go to court?
Most civil cases settle before trial. The defense usually wants to settle once it sees the strength of the evidence. The defense almost always wants to settle once the jury is selected. If the case does not settle, it will go to trial, and you will be asked to testify. We prepare you for testimony, and we are with you in the courtroom. We do not let our clients walk into the courtroom unprepared.
How long will my case take?
The federal case in the Eastern District will likely take two to four years from filing to resolution, depending on the complexity of the case, the discovery disputes, the motion practice, and whether the case settles. A case that goes to trial can take longer. We do not rush a case to settlement. We prepare every case as if it is going to trial, and that preparation is what gets the case to the right number at the right time.
What does it cost to hire you?
We work on a contingency fee. You pay nothing up front. We advance all of the costs of the case. We get paid a percentage of the recovery, one-third if the case settles before trial and forty percent if the case goes to trial. We do not charge hourly. We do not send you a bill. We are paid the same way you are paid: only if we win. The free consultation is yours whether or not you decide to hire us. Past results depend on the facts of each case and do not guarantee future outcomes.
We Are Ready When You Are
If you or someone in your family has been trafficked at a Motel 6 or at any other motel, hotel, or short-term rental in California, the door is open. The first consultation is free. The fee is contingent. We work in English and in Spanish. Hablamos Espanol. We are available 24 hours a day, 7 days a week, on a live line at 1-888-ATTY-911. We will listen, we will tell you the truth, and we will tell you what we can do.
We have walked the Motel 6 properties in San Luis Obispo, Modesto, Redding, Turlock, and Manteca through the legal framework. We have walked the G6 Hospitality corporate structure. We have walked the Oravel Stays acquisition. We have walked the TVPRA, the California Trafficking Victims Protection Act, the constructive-knowledge standard, the franchisor liability theory, the evidence preservation clock, the statute of limitations, the damages range, and the insurance-adjuster playbook. We are ready to walk the case with you.
“Trafficking victims are often unable or unwilling to report their victimization to law enforcement due to language barriers, fear of retaliation, lack of knowledge of their rights, or shame and stigma. Civil liability provides trafficking victims with an important avenue of recourse.” — Findings of the California Legislature, California Civil Code Section 52.5.
The California Legislature is right. Civil liability is the avenue of recourse, and the civil case is the case that gives the survivor her power back. We know how to bring that case. We have been doing this work for more than twenty-four years. We have the journalist’s instinct for the truth, the trial lawyer’s discipline for the courtroom, the insurance defense insider’s knowledge of how the other side fights, the resources to take on a national brand, and the conviction that every survivor of trafficking deserves a lawyer who will fight for her as if the case were the only case.
We are that lawyer. Call us at 1-888-ATTY-911. The first call is free. The call is confidential. Hablamos Espanol. We are here when you are ready. Past results depend on the facts of each case and do not guarantee future outcomes.