You Are Not What Was Done To You
If you are reading this after seeing the news about the trafficking ring broken up across Pennsauken, Maple Shade, and the surrounding counties, you may be in one of two places right now. You may be a survivor trying to understand whether the law offers you anything other than a criminal case you read about. Or you may be a family member who has just realized that the person you love was used in that operation, and that the motels along Route 73 — the Riviera Motor Inn, the Bel-Air Motor Lodge, the Hometown Studios — were more than just buildings where terrible things happened.
We want to tell you something directly before we go any further: the same criminal investigation that put Nathaniel Clay and Shalaby Hicks in jail creates the foundation for a civil case against the motels, the operators, and the corporate structures that took money from the operation while it was happening. That case can result in damages. It can result in your name being protected. It can result in someone paying for the counseling, the medical care, and the lost years.
We handle these cases. We will sit with you in the room. We will not rush you. And we do not get paid unless we win.
This page is written to explain what we see when we look at what just happened in your community, what the law allows you to do about it, and what you need to do in the next 72 hours if you believe you have a claim.
Why the Motels Are a Civil Case, Not Just a Crime Scene
The instinct when you read this story is to see the motels as the backdrop — places where bad people did bad things. That instinct is wrong, and the distinction matters for your case.
The civil law treats the motel as a business that took money from the trafficking operation every single day it was running. Every night a room was rented, the motel got paid. Every night a room was cleaned, the motel got paid. Every night a key was handed over, the motel got paid. The criminal case is about what Clay and Hicks did. The civil case is about what the Riviera Motor Inn, the Bel-Air Motor Lodge, the Hometown Studios, and whoever owns and operates them did with the money that came in through the front desk while all of this was happening.
Three independent legal theories support a civil claim against the motel defendants:
1. The TVPRA civil remedy (federal). The Trafficking Victims Protection Reauthorization Act creates a private right of action under 18 U.S.C. § 1595(a) that allows a survivor to bring a civil case 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 language is broad enough to reach a motel that took room revenue from a trafficking operation it knew — or should have known — was happening at the property.
2. Negligent security under New Jersey law. A New Jersey motel that rents rooms to the public owes its guests a duty of reasonable care. When a motel allows a pattern of cash payments, refused housekeeping, excessive foot traffic, and other warning signs to continue without response, it has failed that duty. The same warning signs the front desk would have seen every day are the warning signs the law says it had a duty to act on.
3. Public nuisance. The operation of a “disorderly house” or drug-trafficking hub creates a public nuisance under New Jersey law, giving rise to specific damages and injunctive relief.
The motel defendants identified in the criminal investigation — the Riviera Motor Inn (Pennsauken), the Bel-Air Motor Lodge (Maple Shade), and the Hometown Studios (Maple Shade) — are direct civil targets. Behind each of them sits a property owner, a manager, and potentially a brand or franchise relationship. The deeper the corporate chain goes, the more money there is to recover. Our job at intake is to map that chain immediately so we name the right defendants from day one.
The Red Flags the Motel Staff Saw (or Should Have Seen)
Federal courts have repeatedly held that a recurring fact pattern at a hotel or motel is enough to plead “should have known” under the TVPRA. The pattern looks like this:
- Cash payments for rooms — no credit card trail, no ID collected
- Frequent refusal of housekeeping — rooms where the same occupant never allows service
- Excessive foot traffic — a stream of different people going to one room at all hours
- Requests for rooms near exits — so the trafficker can move people quickly
- Used condoms, lubricant packaging, unusual trash in hallways or dumpsters
- Fearful or controlled-appearing guests — people who do not speak for themselves, who look to the trafficker before answering
- Prior law-enforcement activity at the property — calls for service, prior reports, prior arrests
- Different young women brought to the same room by the same man, week after week
The hospitality industry trains its staff to recognize these signs precisely because they mean what everyone fears they mean. When a motel on Route 73 ignored them, the law treats that as knowledge.
The criminal case against Clay and Hicks will introduce motel staff testimony, reservation records, and key-card logs that demonstrate exactly this pattern. Our civil case will use the same evidence — and add the motel operator’s own internal communications and incident reports to show what they knew and when they knew it.
The Defendant Map: Who We Sue and Why
The criminal case names Clay and Hicks. The civil case names the people and entities that profited from the operation.
The perpetrators — Nathaniel Clay and Shalaby Hicks. Both are primary tortfeasors. A judgment against them is real money in the abstract and a moral victory in the concrete. The realistic recovery is through their associates and the businesses that took the money.
The motel operators — Riviera Motor Inn (Pennsauken), Bel-Air Motor Lodge (Maple Shade), Hometown Studios (Maple Shade). Each is a direct civil target on negligent-security and TVPRA knowing-benefit theories. Each has its own corporate owner behind it, its own management structure, and its own insurance coverage.
Motel property owners, franchisors, and managers. The named motel is rarely the only defendant. Behind each motel sits a property owner, a management company, a franchisor if the property is part of a chain, and a parent entity. The “shell game” — where each layer points at the next — is the defense’s first move. Our job is to map the structure from the moment we open a file so the right entities are named from day one and no defendant can escape by pointing at the next layer.
Route 73 corridor context. The Route 73 corridor in Pennsauken and Maple Shade has historically been monitored by the New Jersey State Police for transient criminal activity. The jurisdictional overlap of Burlington and Camden counties in this area makes it an ideal environment for multi-county criminal enterprises. The civil case can reach defendants across all four counties involved in the criminal investigation: Camden, Burlington, Middlesex, and Ocean.
The Insurance-Adjuster Playbook (and How We Beat It)
When you file a claim against a motel operator, the insurance company that insures the motel becomes the real opponent. The motel itself is often judgment-proof — a small LLC, a single asset, a thin balance sheet. The insurance policy is where the money lives, and the insurance adjuster is the gatekeeper.
Play #1: “We had no idea.” The adjuster will tell you the motel had no knowledge of the trafficking. Our counter: the same red-flag pattern that the criminal case will document through staff testimony, reservation records, and key-card logs is the same pattern the motel’s own internal communications and incident reports show. We subpoena the internal records. We depose the staff. The “we had no idea” defense does not survive documents.
Play #2: “The criminal case hasn’t convicted anyone yet.” The adjuster will tell you to wait for the criminal case to finish before the civil case moves. Our counter: civil and criminal cases run on separate tracks. The TVPRA statute of limitations is 10 years — the criminal case will not finish that fast. We do not let the criminal case set the civil clock.
Play #3: “You were a willing participant.” The adjuster will argue you were not a victim but a willing participant in commercial sex. Our counter: trafficking victims are not willing participants. The law is clear on this. Tonic immobility — the involuntary freeze response documented in clinical research — happens in the majority of sexual assault victims. We work with trauma-informed clinicians to present the truth of your experience, not the insurance company’s version of it.
Play #4: “You were not our guest.” The adjuster will argue you were not the motel’s invitee, so the motel owed you no duty. Our counter: the TVPRA does not require you to be a “guest” in the traditional sense. The duty arises from the motel’s knowing benefit from the trafficking venture — and from its public-facing function as a lodging provider that invites the public through its doors. The motel’s own marketing materials, its roadside signage, and its reservation process establish the public-invitation element.
Play #5: “Let’s settle this quickly for a small number.” The adjuster may offer a fast settlement for a fraction of what your case is worth, hoping you need the money now. Our counter: we evaluate the offer against the life-care plan, the economist’s report, and the full damages picture. We do not accept lowball offers. We do not let the insurance company set the timeline for your recovery.
Confidentiality: How We Protect Your Identity
We file civil cases for trafficking survivors using the protective mechanisms the law provides. We can file under the pseudonym “Jane Doe” or “John Doe” where the court allows it. We can request that sensitive records be sealed. We can insist that depositions be conducted in a way that protects you from retraumatization.
The criminal case is a matter of public record. The civil case does not have to be. Your name does not have to be in the headline. Your story is yours to tell, in your time, in the way you choose.
The New Jersey human trafficking hotline — 855-363-6548 — is also confidential. If you are not yet ready to talk to a lawyer, the hotline is a place to start.
The Route 73 Corridor and Why This Case Matters Beyond Your Family
We have handled cases against motel operators along highway corridors before. The pattern we see in Pennsauken and Maple Shade is the same pattern we have seen elsewhere: budget motels on a high-traffic corridor, close to transit, with overlapping jurisdictional coverage, where the staff turnover is high, the training is thin, and the incentives favor the cash payment that comes through the door.
The New Jersey Attorney General’s office is right that the FIFA World Cup will draw visitors and predators to the region. The criminal enforcement is real. The civil case is the part that pays the survivors for the damage that was done to them, and that makes the motel operator put real money into the safety practices that should have been in place before any of this happened.
If you or someone you love was victimized at the Riviera Motor Inn, the Bel-Air Motor Lodge, the Hometown Studios, or any other property connected to this case, your civil case is independent of the criminal case, has a 10-year window under federal law, and is aimed at the money that the operation generated. We want to help you recover it.
Frequently Asked Questions
Can I Sue the Motel Where the Trafficking Happened?
Yes. Under the federal Trafficking Victims Protection Reauthorization Act (18 U.S.C. § 1595(a)) and New Jersey common-law negligent-security and public-nuisance theories, a motel that took money from a trafficking operation — and that knew or should have known what was happening on its property — is a civil defendant. The Riviera Motor Inn, the Bel-Air Motor Lodge, and the Hometown Studios are direct targets in this case. The corporate structures behind them may be additional defendants.
How Long Do I Have to File?
Under the federal TVPRA (18 U.S.C. § 1595(c)), you have 10 years from the date the cause of action arose, or 10 years after you turn 18 if the trafficking happened when you were a minor. New Jersey’s general personal-injury statute of limitations is two years under N.J.S.A. 2A:14-2, but for trafficking claims the longer federal window applies. We evaluate both clocks for every client we take.
What If I Did Not Report Right Away?
Delayed disclosure is the norm for trafficking victims, not the exception. The law recognizes this. The DSM-5 criteria for PTSD expressly include a “delayed expression” specifier — full criteria can first appear six months or more after the event. The TVPRA was written with the reality of delayed disclosure in mind. Your delay in reporting does not bar your case.
Will the Motel Try to Blame Me?
The motel’s insurance company will raise every defense it can, including arguments about your conduct. New Jersey follows a modified comparative fault rule with a 51% bar — your own share of fault can reduce your recovery but does not automatically erase it. Trafficking victims are not “at fault” for being victimized. The law has been clear on this for decades. We work with trauma-informed clinicians who can present the truth of your experience to a jury.
Can I Remain Anonymous?
Yes, in most circumstances. We can file your civil case under a pseudonym where the court allows it. We can request that sensitive records be sealed. We can insist on deposition procedures that protect you from retraumatization. Your name does not have to be in the newspaper. Your story is yours to tell, in your time, in the way you choose.
What If I Do Not Have Immigration Papers?
Your immigration status does not affect your right to bring a civil case under the TVPRA or under New Jersey law. The TVPRA’s private right of action is available regardless of immigration status. We represent survivors of trafficking regardless of their immigration circumstances. We do not share your information with immigration authorities.
How Much Will My Case Be Worth?
Cases of this type have resolved in the $1,000,000 to $10,000,000+ range, depending on the number of defendants, the strength of the evidence, the severity of the harm, and the duration of the trafficking. We do not promise a specific number. We build your case with a life-care planner, a forensic economist, and trauma-informed clinicians, and we demand the number the evidence supports. Past results depend on the facts of each case and do not guarantee future outcomes.
What Evidence Will Disappear If I Wait?
Almost all of it. Motel guest registries and folios can be purged under the motel’s own retention policy. Surveillance footage commonly overwrites on a 30-day rolling loop. Police call-for-service records can be archived within a few years. Financial records can be moved. The preservation letter we send on the day you call us is what stops the clock. The day before that letter is a day the evidence can legally be destroyed.
Do I Have to Pay Anything Up Front?
No. We work on contingency. You pay no fee unless we win. Our standard contingency is 33.33% before trial and 40% at trial. We advance the costs of the case. If we do not recover, you owe us nothing.
What If I Already Talked to the Police or the AG’s Office?
That is good. Your statement to the criminal investigators is part of the evidence in your civil case. We coordinate with the prosecutors’ office to make sure the civil case and the criminal case support each other. You do not have to choose between cooperating with the criminal case and pursuing your civil case — they can run in parallel.
What About the Traffickers Themselves — Can I Sue Clay and Hicks?
Yes. They are named defendants in a civil case along with the motel operators, the property owners, and the corporate structures behind them. A judgment against the individual traffickers is real money in the abstract and a moral victory in the concrete. The deeper recovery is through the motels and the businesses that took the operation’s money.
What If the Motel Has Already Been Sold or the Property Has Changed Hands?
We still pursue the case. The corporate structure at the time of the trafficking is what matters for liability. If the property was sold afterward, the prior owner and operator are still defendants. The insurance policy that was in force at the time is still the recovery source. We trace the chain of ownership from the date of the trafficking forward.
How Long Will the Case Take?
Civil trafficking cases typically take one to three years from filing to resolution. Some settle sooner. Some go to trial and take longer. The criminal case in New Jersey will take longer, and the civil case does not wait for it. We keep you informed at every step. We do not let your case sit on a shelf.
Past results depend on the facts of each case and do not guarantee future outcomes. Free consultation. No fee unless we win. Hablamos Español. 1-888-ATTY-911.
Attorney911 — The Manginello Law Firm, PLLC. Learn more about our practice areas. Meet Ralph Manginello and Lupe Peña.
