Christian Morris Trial Attorneys v. Penny L. Barrick, Esq.

• Court: District Court, D. Nevada
• Decided: February 12, 2026
• Docket: 2:25-cv-00797
• Status: Unknown

Opinion

1 CHRISTIAN M. MORRIS, ESQ. 2 Nevada Bar No. 11218 SARAH E. DISALVO, ESQ. 3 Nevada Bar No. 16398 LINDSAY N. ROGINSKI, ESQ. 4 Nevada Bar No. 16616 5 CHRISTIAN MORRIS TRIAL ATTORNEYS 2250 Corporate Circle, Suite 390 6 Henderson, Nevada 89074 T: (702) 434-8282 7 F: (702) 434-1488 8 Christian@CMTAlaw.com Sarah@CMTAlaw.com 9 Lindsay@CMTAlaw.com Attorneys for Plaintiffs 10 -And- 11 PENNY L. BARRICK, ESQ. Ohio Bar No. 74110 (Pro Hac Vice) 12 BABIN LAW, LLC 10 West Broad Street, Suite 900 13 Columbus, Ohio 43215 14 T: (614) 761-8800 penny.barrick@babinlaws.com 15 Attorneys for Plaintiffs

16 UNITED STATES DISTRICT COURT 17 DISTRICT OF NEVADA 18

19 M.B., individually; J.D., individually, D.S., CASE NO: 2:25-cv-00797-CDS-BNW 20 individually, Plaintiffs, 21 vs. 22 STIPULATION AND PROPOSED 23 RED ROOF INNS, INC., RED ROOF ORDER FOR LEAVE TO FILE FRANCHISING, LLC., PARADISE II SECOND AMENDED COMPLAINT 24 LIMITED LIABILITY COMPANY; DOES 1 AND SET BRIEFING SCHEDULE through 10; ROE CORPORATIONS 13 25 through 20; and ABC LIMITED LIABILITY 26 COMPANIES 21 through 30,

27 Defendants.

28 1 Plaintiffs, M.B., J.D., and D.S., (“Plaintiffs”), by and through their counsel of record, 2 Christian M. Morris, Esq., Sarah E. DiSalvo, Esq. and Lindsay N. Roginski, Esq.,; Defendants, 3 RED ROOF INNS, INC., RED ROOF FRANCHISING, LLC., (“Defendant Red Roof”), by and 4 through their counsel of record, Amanda Villalobos, Esq. and Nicholas Janizeh, Esq. of the law 5 6 firm TUCKER ELLIS, LLC; and Defendants Paradise II, LLC, (“Defendant Paradise”), by and 7 through their counsel of record, Whit Selert, Esq., of the law firm O’HAGAN MEYER, PLLC, 8 hereby stipulate and agree as follows: 9 1. Plaintiff seeks leave to file a Second Amended Complaint, pursuant to Federal 10 Rule of Civil Procedure 15(a)(2), for the purpose of amending the parties as follows: 11 12 a. To remove M.B. as a Plaintiff in this litigation matter. 13 2. The Parties agree that Plaintiff may file the proposed Second Amended 14 Complaint, attached hereto as Exhibit 1. 15 3. This stipulation is submitted pursuant to Federal Rule of Civil Procedure 15(a)(2), 16 which provides that a party may amend its pleading with the opposing party’s written consent or 17 18 the court’s leave, and that “leave shall be freely given when justice so requires.” 19 4. The parties further stipulate and request that the Court set the following briefing 20 schedule: 21 a. Defendants’ responses to the Second Amended Complaint shall be due within 22 fourteen (14) days of the filing of the Second Amended Complaint. 23 24 b. Plaintiff shall file any opposition to a Defendant’s motion within fourteen (14) 25 days after service of the motion; 26 c. Any reply in support of a motion filed by a Defendant shall be due within fourteen 27 (14) days after service of Plaintiff’s opposition. 28 5. This stipulation is made in good faith and not for the purpose of delay. 1 IT IS SO ORDERED. 2 DATED this 10th day of February 2026. DATED this 10th day of February 2026. 3 CHRISTIAN MORRIS TRIAL ATTORNEYS TUCKER ELLIS, LLP

4 /s/ Sarah E. DiSalvo /s/ Amanda Villalobos 5 ___________________________________ ________________________________ CHRISTIAN M. MORRIS, ESQ. AMANDA VILLALOBOS, ESQ. 6 Nevada Bar No. 11218 California Bar No. 262176 (Pro Hac Vice) SARAH E. DISALVO., ESQ. NICHOLAS JANIZEH, ESQ. 7 Nevada Bar 16398 California Bar No. 307816 (Pro Hac Vice) 8 2250 Corporate Circle, Suite 390 515 S. Flower St, 42nd Floor Henderson, Nevada 89074 Los Angeles, California 90071 9 Attorneys for Plaintiffs Attorneys for Defendants Red Roof Franchising, Inc. & Red Roof Inns, Inc. 10

11 -AND- -AND-

12 PENNY L. BARRICK, ESQ. REBECCA MASTRANGELO, ESQ. Ohio State Bar No. 74110 (Pro Hac Vice) Nevada State Bar No. 5417 13 BABIN LAW, LLC ROGERS, MASTRANGELO 14 10 W. Broad St., Suite 900 CARVALHO & MITCHELL Columbus, Ohio 43215 700 S. Third St. 15 Attorneys for Plaintiffs Las Vegas, Nevada 89101 Local Counsel for Defendants Red Roof 16 Franchising Inc. & Red Roof Inns, Inc. 17 DATED this 10th day of February 2026. 18 O’HAGAN MEYER, PLLC 19

20 /s/ Whit Selert ________________________________ 21 WHIT SELERT, ESQ. Nevada Bar No. 5492 22 300 S. 4th St., Suite 1250 23 Las Vegas, Nevada 89101 Attorneys for Defendants Paradise II, LLC 24

28 1 ORDER 3 IT IS SO ORDERED. > || DATED:_February 12.2026

Girrenkniniittos— UNI ES MAGISTRATE JUDG . 10 il

17 18 19 20 21 22 23 24 25 26 27 28

Outlook

Re: M.B., ET AL v. Red Roof Inns, et al From Villalobos, Amanda Date Tue 2026-02-10 10:02 To Nicole DuBois Cc Kathryn McCallion ; Rebecca Mastrangelo ; Sarah DiSalvo ; Lindsay Roginski ; Janizeh, Nicholas V. ; Ashley Luto ; Penny Barrick ; Whitney Selert

Yes, thanks! Sent from my iPhone

On Feb 10, 2026, at 11:59AM, Nicole DuBois wrote:

<<< EXTERNAL EMAIL >>>

Thank you, Ms. McCallion, we will make those changes.

Ms. Villalobos, do we have your permission to e-sign?

Best regards, Nicole DuBoiy Paralegal “Kindness ix the culture. Justice is the purpose.” 2250 Corporate Circle Suite 390 Henderson NV 89074 Direct Tel: 702-763-6904 Direct Fax: 702-728-2565 Office Tel: 702-434-8282 Nicoled@cmtalaw.com CMTrialAttorneys.com CONFIDENTIALITY NOTICE: This email and any attachments are for the exclusive and confidential use of the intended recipient. If you are not the intended recipient, please do not read, distribute or take action in reliance upon this message. If you have received this in error,

please notiry us immealately by return emall ana promptly aelete Chis message ana 1ts attachments from your computer system. We do not waive attorney-client or work product privilege by the transmission of this message.

From: Kathryn McCallion Sent: Monday, February 9, 2026 07:59 To: Nicole DuBois ; Villalobos, Amanda ; Rebecca Mastrangelo Cc: Sarah DiSalvo ; Lindsay Roginski ; Janizeh, Nicholas V. ; Ashley Luto ; Penny Barrick ; Whitney Selert Subject: RE: M.B., ET AL v. Red Roof Inns, et al Good morning, Please remove John Orr, Esq. and my name from the Stipulation and keep Whit Selert, Esq. as the attorney of record. No other changes are needed on our end. You have authority to e-sign on behalf of Whit Selert, Esq. Thank you, Kathryn McCallion Associate Attorney 1717 Arch Street | Suite 3910 | Philadelphia | PA| 19103 PH 215.461.3300 | DIR 215.461.3352| FAX 215.461.3311

INFORMATION IN THIS TRANSMITTAL IS CONFIDENTIAL AND INTENDED ONLY FOR THE RECIPIENT LISTED ABOVE. IF YOU ARE NEITHER THE INTENDED RECIPIENT NOR A PERSON RESPONSIBLE FOR DELIVERING THIS TRANSMITTAL TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISTRIBUTION OR COPYING OF THIS TRANSMITTAL IS PROHIBITED. IF YOU RECEIVED THIS TRANSMITTAL IN ERROR, PLEASE IMMEDIATELY NOTIFY US BY TELEPHONE OR EMAIL AND IMMEDIATELY DELETE THE MESSAGE. From: Nicole DuBois Sent: Thursday, February 5, 2026 12:31 PM To: Villalobos, Amanda ; Rebecca Mastrangelo ; Kathryn McCallion Cc: Sarah DiSalvo ; Lindsay Roginski ; Janizeh, Nicholas V. ; Ashley Luto ; Penny Barrick ; Whitney Selert Subject: [EXTERNAL] Re: M.B., ET AL v. Red Roof Inns, et al CAUTION: This email originated from outside the organization.

Good worning,

EXHIBIT 1

2nd Amended Complaint

EXHIBIT 1 1 CHRISTIAN M. MORRIS, ESQ. Nevada Bar No. 11218 2 SARAH E. DISALVO, ESQ. 3 Nevada Bar No. 16398 LINDSAY N. ROGINSKI, ESQ. 4 Nevada Bar No. 16616 CHRISTIAN MORRIS TRIAL ATTORNEYS 5 2250 Corporate Circle, Suite 390 6 Henderson, Nevada 89074 T: (702) 434-8282 7 F: (702) 434-1488 Christian@CMTAlaw.com 8 Sarah@CMTAlaw.com 9 Lindsay@CMTAlaw.com Attorneys for Plaintiffs 10 -And- PENNY L. BARRICK, ESQ. 11 Ohio Bar No. 74110 (Pro Hac Vice) 12 BABIN LAW, LLC 10 West Broad Street, Suite 900 13 Columbus, Ohio 43215 T: (614) 761-8800 14 penny.barrick@babinlaws.com 15 Attorneys for Plaintiffs UNITED STATES DISTRICT COURT 16 DISTRICT OF NEVADA 17

18 J.D., individually, D.S., individually, CASE NO.: 2:25-cv-00797-CDS-BNW 19

20 Plaintiffs,

21 vs. SECOND AMENDED COMPLAINT

22 RED ROOF INNS, INC., RED ROOF 23 FRANCHISING, LLC., PARADISE II LIMITED LIABILITY COMPANY; DOES 1 24 through 10; ROE CORPORATIONS 13 through 20; and ABC LIMITED LIABILITY 25 COMPANIES 21 through 30, 26 Defendants. 27 28 COMES NOW, Plaintiffs, J.D., individually; and D.S. individually by and through their 1 counsel of record, Christian M. Morris, Esq., Sarah E. DiSalvo, Esq., and Lindsay N. Roginski, 2 Esq., of the law firm CHRISTIAN MORRIS TRIAL ATTORNEYS, for their causes of action 3 against Defendants above named, and each of them, and complain and allege as follows: 4 INTRODUCTION 5 The Las Vegas Red Roof Inn was a notorious epicenter of sex trafficking. Defendants 6 Red Roof Inns, Inc., Red Roof Franchising, LLC, and Paradise II Limited Liability Company 7 (hereinafter “Defendants”) exploited victims of sex trafficking, deliberately ignoring blatant 8 signs of abuse to maximize their profits. Defendants prioritized financial gains over the lives and 9 dignity of countless victims, creating an environment where traffickers could operate with 10 impunity. Defendants’ willful negligence and active complicity demonstrate a shocking 11 disregard for human life, as they knowingly facilitated the systematic abuse and exploitation of 12 vulnerable individuals for years. Plaintiffs J.D., and D.S., are two of many vulnerable individuals 13 who were coerced into sex trafficking, forced into commercial acts, and subjected to abuse, all 14 while Defendants turned a blind eye to their suffering. Defendants and their staff consistently 15 ignored clear indicators and reports of sex trafficking at the Las Vegas Red Roof Inn, allowing 16 their property to become a hub for sex trafficking, profiting from the repeated bookings and 17 extending stays while countless lives were shattered within its walls. 18 PARTIES 19 1. Plaintiff J.D. is and at all times relevant hereto was a resident of Hamilton County, 20 Ohio. 21 2. Plaintiff D.S. is and at all times relevant hereto was a resident of Riverside 22 County, California. 23 3. Plaintiffs J.D. and D.S., (hereinafter “Plaintiffs”), are victims of trafficking 24 pursuant to 22. U.S.C. § 7102(12), 22. U.S.C. § 7102(16), 22. U.S.C. § 7102(17), 18 U.S.C. § 25 1591(a), and 18 U.S.C. § 1595. 26 4. Due to the sensitive and intimate nature of the issues, Plaintiffs J.D. and D.S., 27 request that this Court grant a protective order pursuant to Fed. R. Civ. P. 26(c) to permit them 28 to proceed under a pseudonym and to ensure that Defendants maintain the confidentiality of 1 Plaintiffs identities during this lawsuit and thereafter.1 2 5. Generally, under the Federal Rules of Civil Procedure, pleadings must state the 3 name of all parties.2 However, there are exceptions when the issues involved are of a sensitive 4 and highly personal nature.3 For good cause, the Court may issue an order to protect a party or 5 person from annoyance, embarrassment, oppression or undue burden or expense. 4 6 6. Here, granting pseudonym status and proceeding under seal is warranted because 7 this litigation will involve the disclosure of stigmatizing sexual information, including rape. 8 Plaintiffs J.D., and D.S., fear the stigma from their families, friends, employers, and communities 9 if their true identities are revealed in the public record. 10 7. Additionally, disclosing the identities of Plaintiffs J.D. and D.S., may put their 11 safety at risk. Victims of trafficking often face serious harm, including threats, violence, and 12 retaliation, when they take legal action against their traffickers or those associated with them. In 13 some cases, this danger can escalate to severe injury or even loss of life. 14 8. Plaintiffs J.D. and D.S., should not be compelled to disclose their identities in 15 order to maintain their privacy and safety. Plaintiffs’ privacy interests substantially outweigh the 16 customary practice of judicial openness.5 17 9. Moreover, Defendants will not be prejudiced by Plaintiffs proceeding under 18 pseudonyms. Plaintiffs J.D. and D.S., are willing to disclose their identities to Defendants for 19

20 1 In cases where the plaintiffs have demonstrated a need for anonymity, the district court should use its powers to 21 manage pretrial proceedings under Fed. R. Civ. P. 16(b), and to issue protective orders limiting disclosure of the party’s name under Fed. R. Civ. P. 26(c), to preserve the party’s anonymity to the greatest extent possible without 22 prejudicing the opposing party’s ability to litigate the case. Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1069 (9th Cir. 2000). 23 2 Fed. R. Civ. P. 10(a). 3 A district court must balance the need for anonymity against the general presumption that the parties’ identities are 24 public information and the risk of unfairness to the opposing party. See, e.g., M.M. v. Zavaras, 139 F.3d 798, 803 (10th Cir.1998); James v. Jacobson, 6 F.3d at 238 (4th Cir. 1993); Doe v. Frank, 951 F.2d 320, 323–24 (11th 25 Cir.1992); Doe v. Stegall, 653 F.2d at 186 (5th Cir.); see also Doe v. Frank at 323 (11th Cir. 1992) (holding that a plaintiff should be permitted to proceed anonymously in cases involving matters of a highly sensitive and personal 26 nature, real danger of physical harm, or where the injury litigated against would be incurred as a result of the disclosure of the plaintiff’s identity). 27 4 Fed. R. Civ. P. 26(c). 5 Does I thru XXIII, 214 F.3d at 1068 (joining its 4th, 5th, 10th, and 11th sister circuits in holding that a party may 28 preserve his or her anonymity in judicial proceedings in special circumstances when the party’s need for anonymity outweighs prejudice to the opposing party and the public’s interest in knowing the party’s identity). 1 the limited purpose of investigating their claims, provided that a protective order is in place. 2 Accordingly, Plaintiffs J.D. and D.S., simply seek redaction of their personal identifying 3 information from the public docket and assurances that Defendants will not disclose or publish 4 their identities due to the sensitive and intimate nature of this case. Plaintiffs J.D. and D.S., 5 request that this Court grant a protective order pursuant to Fed. R. Civ. P. 26(c) to allow them to 6 proceed under pseudonyms and to ensure the confidentiality of their identities both during and 7 after this litigation, safeguarding their safety, personal lives, relationships, and future 8 employment prospects. 9 10. Defendant RED ROOF INNS, INC. (hereinafter “Defendant RRI”) is a foreign 10 corporation incorporated under the laws of the State of Delaware, with its corporate headquarters 11 and principal place of business located in Ohio, and at all times relevant was doing business in 12 Clark County, Nevada. 13 11. Defendant RED ROOF FRANCHISING, LLC (hereinafter “Defendant RRF”), is 14 a foreign limited liability acting under the laws of the State of Delaware, with its corporate 15 headquarters and principal place of business Ohio, and at all times relevant was doing business 16 in Clark County, Nevada. 17 12. Upon information and belief, Defendants RRI and RRF (hereinafter “The Red 18 Roof Inn Defendants”) purchase, own, franchise, and/or manage a network of approximately six 19 hundred and fifty (650) hotels and motels globally. 20 13. Defendant PARADISE II LIMITED LIABILITY COMPANY (hereinafter 21 “Defendant Paradise”) was a limited liability company acting under the laws of the State of 22 Nevada, and at all times relevant was doing business in Clark County, Nevada as the franchisee 23 and operator of the Las Vegas Red Roof Inn located at 4350 Paradise Road, Las Vegas, Nevada 24 89169 (hereinafter “The Las Vegas Red Roof Inn”). 25 14. Defendants RRI, RRF, Paradise (hereinafter, “Defendants”), and each of them, 26 participated in a joint venture operating as the Las Vegas Red Roof Inn, which permanently 27 closed at the end of 2024. 28 15. Upon information and belief, the Red Roof Inn Defendants maintain a pervasive 1 brand presence at their properties, including the Las Vegas Red Roof Inn, through prominent 2 internal and external signage, staff uniforms, and branded in-room amenities such as pens and 3 notepads. This comprehensive branding strategy ensures a consistent guest experience aligned 4 with the Red Roof Inn Defendants’ standards, which Defendant Paradise must follow. 5 16. Upon information and belief, the Red Roof Inn Defendants mandate specific 6 vendors, suppliers, and IT systems for branded hotels, including Las Vegas Red Roof, 7 maintaining control over operations through a consolidated network, which Defendant Paradise 8 must follow. 9 17. Upon information and belief, the Red Roof Inn Defendants charge approximately 10 10% of gross revenue for brand usage, provide marketing and centralized booking systems, and 11 allocate resources for monitoring brand standards and training of the Red Roof Inn Defendants’ 12 employees and the Red Roof Inn Defendants and Defendant Paradise’s employees, agents, 13 and/or staff at the Las Vegas Red Roof Inn for whom these Defendants jointly employ. 14 18. Upon information and belief, the Red Roof Inn Defendants retain authority to 15 enforce standards through inspections and franchise termination, exercising significant control 16 over employment decisions and daily operations of Defendant Paradise’s Las Vegas Red Roof 17 Inn. 18 19. Upon information and belief, Defendant Paradise, as the franchisee of the Las 19 Vegas Red Roof Inn, directly oversaw its management, including: 20 a. Managing business operations; 21 b. Overseeing room rentals, including use of the Red Roof Inn Defendants’ database 22 of room availability and occupancy; 23 c. Training and jointly employing employees and staff in accordance with the Red 24 Roof Inn Defendants’ requirements; 25 d. Earning revenue from the operation of Las Vegas Red Roof Inn; 26 e. Assisting in the establishment of Las Vegas Red Roof as a business venture; 27 f. Communicating, working with, and complying with the Red Roof Inn Defendants 28 regarding the operation of the Las Vegas Red Roof Inn; 1 g. Managing the Red Roof Inn Defendants’ who monitor the internet and social 2 media presence, including reputation management, and the collection of customer 3 data 4 20. Upon information and belief, the Red Roof Inn Defendants exercised significant 5 control over the Las Vegas Red Roof Inn’s operations, policies, procedures, and business 6 practices, such as: 7 a. Providing specifications for the Las Vegas Red Roof Inn’s physical structure; 8 b. Assisted with the grand opening of the Las Vegas Red Roof Inn in compliance 9 with the Red Roof Inn Defendants’ contracts, policies and standards; 10 c. Communicating, monitoring, reviewing, and grading compliance with Defendant 11 Paradise about the operations of the Las Vegas Red Roof Inn; 12 d. Requiring Defendant Paradise to participate in training sessions and meetings 13 with the Red Roof Inn Defendants; 14 e. Established and dictated policies, procedures, and training related to safety, 15 security, and response protocols at the Las Vegas Red Roof Inn; 16 f. Required the use of the Red Roof Inn Defendants’ reservations system at the Las 17 Vegas Red Roof Inn, which the Red Roof Inn Defendants oversaw and controlled; 18 g. Managed, Operated, Monitored and Processed payment information for guests at 19 the Las Vegas Red Roof Inn through the Red Roof Inn Defendants’ corporate 20 systems; 21 h. Received benefits from room rentals at the Las Vegas Red Roof Inn, governed by 22 the franchising agreement between Defendant Paradise and the Red Roof Inn 23 Defendants. 24 i. Exercised joint control over the Las Vegas Red Roof Inn; 25 j. Provided and required the use of branded clothes and other service goods to 26 Defendant Paradise, for the operation of the Las Vegas Red Roof Inn; 27 k. Managed, monitored, operated, the social media and online presence of the Las 28 Vegas Red Roof Inn; 1 l. Provided and required the use of the software, hardware, and platforms for data 2 sharing with the Red Roof Inn Defendants; 3 m. Provided and required the use of reservation platforms where payment methods 4 and suspicious reservations could indicate trafficking at the Las Vegas Red Roof 5 Inn; 6 n. Provided franchise and brand support to Defendant Paradise through back-end 7 management;6 8 o. Provided training and education to Defendant Paradise’s Las Vegas Red Roof Inn 9 employees, agents, and/or staff through webinars, seminars, conferences, and 10 online portals; 11 p. Provided, controlled, and maintained customer review and response platforms 12 and third party vendor platforms of same; 13 q. Required the use of online bookings on Red Roof’s domain; 14 r. Required Defendant Paradise’s Las Vegas Red Roof Inn to use Red Roof’s 15 customer rewards program, property management software, and approved 16 vendors for internet services, Wi-Fi access, and filtering; 17 s. Provided IT support to Defendant Paradise for all property management systems, 18 owned, operated, and required by the Red Roof Inn Defendants; 19 t. Set employee wages of Defendant Paradise’s Las Vegas Red Roof Inn employees, 20 agents, and/or staff; 21 u. Created standardized employee training methods and mandating strict operating 22 rules for Defendant Paradise’s Las Vegas Red Roof Inn employees, agents, and/or 23 staff; 24 v. Conducted regular inspections of the Las Vegas Red Roof Inn’s facilities and 25

26 6 See e.g., Brand Support, RED ROOF, (last visited April 15, 2025), https://www.redrooffranchising.com/brand- 27 support, (“We support our franchisees with extensive on-site training. On everything from helping with pricing strategy and operational expense management, to assistance with marketing and operation programs…Our cost- 28 effective sourcing solutions, efficient technology support, and incredible property management system add even more value to your Red Roof franchise.”) 1 operations; 2 w. Fixed profit margins; and 3 x. Shared profits. 4 21. Upon information and belief, Plaintiffs’ claims against the Red Roof Inn 5 Defendants arise out of their actual and apparent agency relationship with their branded hotels, 6 including Defendant Paradise’s Las Vegas Red Roof Inn, where Plaintiffs were trafficked. The 7 Red Roof Inn Defendants are liable directly, vicariously, and indirectly through an agency 8 relationship for the acts and/or omissions of the employees at their branded hotels, including the 9 Las Vegas Red Roof Inn. 10 22. Furthermore, the Red Roof Inn Defendants benefited from operations at Las Vegas 11 Red Roof Inn beyond royalty payments and licensing fees. Defendants gathered and utilized data 12 from guests, traffickers, and “Purchasers” or “Johns” who accessed internet/Wi-Fi services, 13 further enhancing Defendants’ financial and marketing advantages. 14 23. Upon information and belief, the Red Roof Inn Defendants are vicariously liable 15 for the acts and omissions of its agents, branded properties, Defendant Paradise, and any sub- 16 agents or employees operating at its branded properties, including Las Vegas Red Roof. Due to 17 the Red Roof Inn Defendants’ extensive control over the operations, staffing, and management 18 of its branded hotels, including the oversight of security, reporting mechanisms, and operational 19 standards, the Red Roof Inn Defendants are responsible for the actions taken at the Las Vegas 20 Red Roof Inn. 21 24. Plaintiff is informed, believes and thereon alleges that all of the acts, omissions 22 and conduct described below of each, and every Defendant was duly authorized, ordered, and 23 directed by the respective and collective Defendant corporate employers, officers, and 24 management-level employees of said corporate employers. In addition thereto, said corporate 25 employers participated in the aforementioned acts and conduct of their said employees, agents 26 and representatives and each of them; and upon completion of the aforesaid acts and conduct of 27 said corporate employees, agents and representatives, the Defendant corporations, respectively 28 and collectively, ratified, accepted the benefits of, condoned, lauded, acquiesced, approved, and 1 consented to each and every of the said acts and conduct of the aforesaid corporate employees, 2 agents and representatives. 3 25. The true names and capacities, whether individual, corporate, associate, 4 governmental or otherwise, of defendants designated herein as DOES 1 through 10; ROE 5 CORPORATIONS 11 through 20, and ABC LIMITED LIABILITY COMPANIES 21 through 6 30, (“DOES/ROE CORPORATIONS/ABC LIMITED LIABILITY COMPANIES Defendants”), 7 inclusive, are unknown to Plaintiffs at this time, who therefore sue said Defendants by such 8 fictitious names. When the true names and capacities of said Defendants have been ascertained, 9 Plaintiffs will amend this Complaint accordingly, and reserve the right to do so at the appropriate 10 time. 11 26. Plaintiffs are informed, believe, and thereon allege that DOES/ROE 12 CORPORATIONS/ABC LIMITED LIABILITY COMPANIES Defendants are responsible, 13 negligently or in some other actionable manner, for the events and happenings hereinafter referred 14 to, and caused injuries and damages proximately thereby to Plaintiffs as hereinafter alleged. 15 27. Plaintiffs are informed, believe and thereon allege that DOES/ROE 16 CORPORATIONS/ABC LIMITED LIABILITY COMPANIES Defendants were involved in the 17 initiation, approval, support or execution of the wrongful acts upon which this litigation is 18 premised, or of similar actions against Plaintiffs of which Plaintiffs are presently unaware or 19 without adequate knowledge. 20 28. Plaintiffs are informed, believe, and thereon allege that DOES/ROE/ABC 21 Defendants are predecessors-in-interest, successors-in-interest, and/or agencies otherwise in a 22 joint venture with, and/or serving as an alter ego of, any and/or all defendants named herein; 23 and/or are entities employed by and/or otherwise directing the individual Defendants in the scope 24 and course of their responsibilities at the time of the events and circumstances alleged herein; 25 and/or are entities otherwise contributing in any way to the acts complained of and the damages 26 alleged to have been suffered by Plaintiffs herein. Upon information and belief, each of the 27 defendants designated as DOES/ROE/ABC is in some manner vicariously and/or statutorily 28 responsible for the events alleged by this Complaint and actually, proximately, and/or legally 1 caused damages to Plaintiffs. 2 29. Defendants, and each of them, were the apparent and ostensible principals, 3 apparent and ostensible agents, agents, apparent and ostensible servants, servants, apparent and 4 ostensible employees, employees, apparent and ostensible assistants, assistants, apparent and 5 ostensible consultants, and consultants of their Co-Defendants, and were acting as such within 6 the course, scope, and authority of said agency and employment, and that each of the defendants, 7 as aforesaid, when acting as a principal, was in some manner responsible for the events alleged 8 herein as an agent, servant, employee, assistant, and consultant. 9 30. Every act or omission of the Defendants and their apparent and ostensible 10 principals, principals, apparent and ostensible agents, agents, apparent and ostensible servants, 11 servants, apparent and ostensible employees, apparent and ostensible assistants, assistants, 12 apparent and ostensible consultants, and consultants of their Co-Defendants, whether or not 13 within the scope of their agency, was ratified by the other remaining Defendants. 14 JURISDICTION AND VENUE 15 31. Plaintiffs repeat and reallege each and every allegation contained above as though 16 fully set forth herein. 17 32. This Federal District Court has jurisdiction over this action pursuant to 28 U.S.C. 18 § 1331 because Plaintiffs’ claims arise under federal law, specifically the Trafficking Victims 19 Protection Reauthorization Act (TVPRA), 18 U.S.C. § 1595. 20 33. This Federal District Court has personal jurisdiction over Defendants RRI, RRF, 21 and Paradise, pursuant to Fed. R. Civ. P. 4(k)(1)(A) and Nevada's long-arm statute, NRS 14.065, 22 because Defendants Red Roof Inns, Inc., and Red Roof Franchising, LLC have purposefully 23 availed themselves of the privilege of conducting business activities within Nevada. Further, Red 24 Roof Inn Defendants have established minimum contacts with Nevada through their ownership, 25 operation, and/or control of the hotel property where Plaintiffs were trafficked, as well as their 26 continuous and systematic business activities in Nevada as outlined above. 27 34. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)(2) because a 28 substantial part of the events or omissions giving rise to Plaintiffs’ claims occurred in this District. 1 Specifically, Plaintiffs were trafficked at the Las Vegas Red Roof Inn, located within this District. 2 35. Venue is also proper in this District pursuant to 28 U.S.C. § 1391(b)(3), as this 3 Federal District Court has personal jurisdiction over Defendants RRI and RRF. 4 SEX TRAFFICKING UNDER FEDERAL LAW 5 36. Plaintiffs repeat and reallege each and every allegation contained above as though 6 fully set forth herein. 7 37. The requirement for liability under the Trafficking Victims Protection 8 Reauthorization Act (“TVPRA”) § 1595, based on a beneficiary theory, can be stated as follows: 9 (1) the person or entity “knowingly benefits, financially or by receiving anything of value”; (2) 10 “from participating in a venture”; which (3) the “person knew or should have known has engaged 11 in an act in violation of this chapter.” 18 U.S.C. § 1595(a). 12 38. Sex trafficking' is defined by the TVPRA under 22 U.S.C. § 7102(12) as "the 13 recruitment, harboring, transportation, provision, obtaining, patronizing, or soliciting of a person 14 for the purpose of a commercial sex act." 15 39. “Commercial Sex Act” is defined as any sex act for which anything of value is 16 given to or received by a person. 22 U.S.C. § 7102(4). 17 40. “Severe Forms of Trafficking in Persons” is defined as any instance of sex 18 trafficking where: (a) a commercial sex act is induced by force, fraud, or coercion; or (b) the 19 person induced to perform such an act is under eighteen (18) years of age. 22 U.S.C. § 7102(11). 20 41. Pursuant to 18 U.S.C. § 1591(a), all who knowingly provide or obtain commercial 21 sex that was provided or obtained through force, fraud, and coercion, or "cause a person to engage 22 in a commercial sex act" are guilty of sex trafficking. This includes, at a minimum, both the 23 'traffickers' who recruit, harbor, transport, and provide individuals for forced commercial sex 24 work and the 'Johns' or 'buyers' who obtain, solicit, or patronize forced commercial sex work. 25 42. 18 U.S.C. § 1595 provides for a beneficiary liability claim against "whoever 26 knowingly benefits, or attempts or conspires to benefit, financially or by receiving anything of 27 value from participation in a venture which that person knew or should have known has engaged 28 in an act in violation” of the TVPRA. See 18 U.S.C. § 1595(a). 1 GENERAL ALLEGATIONS 2 43. Plaintiffs repeat and reallege each and every allegation contained above as though 3 fully set forth herein. 4 44. The Sex Trafficking industry generates approximately $236 Billion annually7, 5 making it the second-largest criminal trade after the sale of illegal drugs.8 6 45. Traffickers use hotel and motel rooms as hubs for their operations,9 where victims 7 are harbored, raped, assaulted, and forced to service buyers. The hospitality industry has made 8 millions by participating in ventures that it knew or should have known engaged in violations of 9 the TVPRA, under 18 U.S.C. §1591(a). 10 46. Due to the prevalent connection between hotels and sex trafficking, government 11 agencies and nonprofits including the United States Department of Homeland Security, the 12 National Center for Missing and Exploited Children, the Polaris Project, the United States 13 Department of Transportation, various attorney generals, and the End Child Prostitution and 14 Trafficking (hereinafter “ECPAT”), among others, have extensively educated the hotel industry, 15 including Red Roof, on identifying and responding to sex trafficking incidents and have 16 established recommended policies and procedures for recognizing signs of sex trafficking.10 11 17 18 7 Rosalyn Roden, Traffickers taking $236 billion in illegal profits at victims’ expense, Hope for Justice (citing International Labor Organization’s 2024 report), (last visited April 15, 2025), 19 https://hopeforjustice.org/news/traffickers-taking-236-billion-in-illegal-profits-at-victims-expense/ 8 Transnational organized crime: the globalized illegal economy, United Nations Office on Drugs, (last visited 20 April 15, 2025), https://www.unodc.org/toc/en/crimes/organized-crime.html 21 9 Bradley Myles, Combating Human Trafficking in the Hotel Industry, HUFFINGTON POST (last visited April 15, 2025), https://www.huffpost.com/entry/combating-human-trafficking-in-the-hotel-industry_b_7840754 22

23 10 Department of Homeland Security, Blue Campaign Toolkit, (last visited April 15, 2025) https://www.dhs.gov/sites/default/files/publications/blue-campaign/toolkits/hospitality-toolkit-eng.pdf; National 24 Center for Missing & Exploited Children, Child Sex Trafficking Overview, (last visited April 15, 2025), https://www.missingkids.org/content/dam/missingkids/pdfs/CST%20Identification%20Resource.pdf; Love 146, 25 Red Flags for Hotel and Motel Employees, (last visited April 15, 2025), https://love146.org/wp- content/uploads/2017/04/Hospitality-Red-Flag-and-Reporting-Love146.pdf; Texas Attorney General, Human 26 Trafficking Red Flags, (last visited April 15, 2025) https://www2.texasattorneygeneral.gov/files/human_trafficking/human_trafficking_red_flags_handout.pdf . 27 11 United States Department of Homeland Security Blue Campaign – One Voice. One Mission. End Human Trafficking, (last visited April 15, 2025), https://www.dhs.gov/sites/default/files/publications/blue- 28 campaign/toolkits/hospitality-toolkit-eng.pdf; National Center for Missing and Exploited Children, Trafficking Risk 1 47. Indicators of sex trafficking in a hotel environment follow a well-known pattern 2 and are easily detectable by appropriately trained staff. Various organizations have developed 3 human trafficking “tool kits,” which help hotel staff in every position identify and respond to 4 signs of sex trafficking.12 From check-in to check-out, there are indicators that traffickers and 5 their victims exhibit during their stay at the hotel. 6 48. Despite this knowledge, the hotel industry continues to prioritize profits over 7 victims' safety. While hospitality corporations swiftly adapted their business practices to respond 8 to the COVID-19 pandemic, they have remained inactive in the face of the human trafficking 9 crisis. This failure to take meaningful action has led to the repeated sexual abuse and rape of 10 victims on their properties. 11 49. Defendants, and each of them, systematically failed to create, adopt, implement, 12 and enforce anti-trafficking policies. This failure persists despite the availability of resources and 13 training programs specifically designed for the hospitality industry to combat human trafficking. 14 50. Defendants, and each of them, neglected to provide staff with necessary training 15 to identify and respond to trafficking, and failed to mandate brand-wide training, allowing 16 trafficking to persist unchecked. 17 51. Defendants, and each of them, have actively profited from renting rooms where 18 victims are forced into commercial sex against their will. 19 52. Plaintiffs in this case are survivors of sex trafficking, seeking justice through the 20 judicial system, which Congress has empowered to provide remedies under the TVPRA. Under 21 18 U.S.C. § 1595 Defendants, and each of them, knowingly benefited from participation in a 22

23 Factors, https://www.missingkids.org/theissues/trafficking#riskfactors (last visited April 15, 2025); Love 146, Red 24 Flags for Hotel & Motel Employees, (last visited April 15, 2025), https://love146.org/wp- content/uploads/2017/04/Hospitality-Red-Flag-and-Reporting-Love146.pdf; Texas Attorney General, Human 25 Trafficking Red Flags, (last visited April 15, 2025) https://www2.texasattorneygeneral.gov/files/human_trafficking/human_trafficking_red_flags_handout.pdf (last 26 visited April 15, 2025); U.S. Department of Transportation, Indicators of Human Trafficking, (last visited April 15, 2025), https://www.transportation.gov/stop-human-trafficking/indicators; Ohio Attorney General, Human 27 Trafficking Initiative, (last visited April 15, 2025), https://www.ohioattorneygeneral.gov/Individuals-and- Families/Victims/Human-Trafficking. 28 12 E.g., Department of Homeland Security, Blue Campaign Toolkit, (last visited April 15, 2025), https://www.dhs.gov/sites/default/files/publications/blue-campaign/toolkits/hospitality-toolkit-eng.pdf 1 venture that it knew or should have known to be in engaging in violations of 18 U.S.C. § 1591(a). 2 53. Plaintiffs have suffered severe injuries as a result of their prolonged exploitation, 3 including ongoing mental, emotional, and psychological trauma. Because these injuries cannot be 4 separated or assigned to a single Defendant, federal common law provides for joint and several 5 liability, making all violators of Section 1595 of the TVPRA liable for a victim's damages. 6 Plaintiffs are entitled to all compensatory and non-compensatory damages incurred during their 7 trafficking period. 8 54. The hospitality industry cannot continue to feign ignorance while profiting from 9 the exploitation of trafficking victims. Defendants, and each of them, must be held accountable 10 for their knowing participation in ventures that violate the TVPRA, prioritizing financial gain 11 over the safety and dignity of the individuals who have suffered under their watch. 12 DEFENDANTS’ ACTUAL AND CONSTRUCTIVE KNOWLEDGE OF SEX 13 TRAFFICKING AT THE LAS VEGAS RED ROOF INN 14 55. Plaintiffs repeat and reallege each and every allegation contained above as though 15 fully set forth herein. 16 56. Defendants are aware that the hospitality industry serves as a primary facilitator 17 of human trafficking, both domestically and internationally.13 The United Nations,14 international 18 non-profit organizations,15 and the U.S. Department of Homeland Security,16 have documented 19 this well-known epidemic of human trafficking for years and brought particular attention to the 20 21 13 Giovanna L. C. Cavagnaro, Sex Trafficking: The Hospitality Industry’s Role and Responsibility, CORNELL UNIVERSITY SCHOOL OF HOTEL ADMINISTRATION, (last visited April 15, 2025) 22 https://ecommons.cornell.edu/items/62deb32c-ce31-4780-bb95-7827509a8890. 14 UNITED NATIONS OFFICE ON DRUGS AND CRIME, Global Report on Trafficking in Persons, (last visited 23 April 15, 2025), https://www.unodc.org/documents/data-and-analysis/tip/2021/GLOTiP_2020_15jan_web.pdf; See also, UNITED NATIONS OFFICE ON DRUGS AND CRIME, We must act together to fight exploitation and 24 human trafficking in tourism, say United Nations and international partners, (last visited April 15, 2025), https://www.unodc.org/unodc/en/press/releases/2012/April/we-must-act-together-to-fight-exploitation-and-human- 25 trafficking-in-tourism-say-united-nations-and-international-partners.html 15 The Polaris Project and ECPAT-International have published extensive reports and professional toolkits on 26 human trafficking in the hospitality industry for years. 16 U.S. Department of Homeland Security, Human Trafficking and the Hospitality Industry, (last visited April 15, 27 2025), https://www.dhs.gov/archive/blue-campaign/human-trafficking-and-hospitality-industry; U.S. Department of Homeland Security, Blue Campaign Toolkit, (last visited April 15, 2025), 28 https://www.dhs.gov/sites/default/files/publications/blue-campaign/toolkits/hospitality-toolkit-eng.pdf 1 indispensable role of hotels. 2 57. Since 2004, initiatives like ECPAT-USA launched the Tourism Child-Protection 3 Code of Conduct (hereinafter the “Code”) in the United States outlining specific hotel practices 4 to prevent sex trafficking, such as: (1) prohibiting hourly room rates; (2) disallowing cash 5 payments for accommodations; (3) monitoring online platforms for sex advertisements 6 mentioning the hotel's name or featuring images of its rooms; (4) implementing regular changes 7 to internet and Wi-Fi passwords in guest rooms and public areas; (5) tracking patterns of frequent 8 visitors to specific rooms; (6) maintaining vigilance for rooms with excessive quantities of 9 prophylactics, lubricants, and towels; and (7) mandating the registration of all visitors, including 10 detailed information such as guest name, visitor name, arrival and departure times, and room 11 number. 12 58. The Red Roof Defendants are signatories of The Code an anti-trafficking initiative 13 developed by ECPAT, committing to policies aimed at combating human trafficking. Despite this 14 commitment, Red Roof failed to implement anti-trafficking measures at its branded properties, 15 continuing to profit from trafficking and exploitation occurring at its locations. 16 59. As a signatory to ECPAT, the Red Roof Defendants publicly committed to follow 17 the organization’s anti-trafficking guidance and participate in programs to prevent sex trafficking 18 at its hotels. Consequently, Red Roof was obligated to establish and enforce effective standards, 19 mandates, and operational measures to combat trafficking within its properties. 20 60. In 2022, the Red Roof Defendants deepened its partnership with ECPAT-USA by 21 launching an industry-wide fundraising campaign at the Asian American Hotel Owners 22 Association Conference (AAHOACON). Red Roof began the campaign with a $10,000 donation, 23 seeking to rally the hospitality industry to combat human trafficking.17 Despite publicly 24 promoting this effort and claiming to prioritize anti-trafficking measures, Red Roof failed to 25 enforce the policies necessary to prevent trafficking and exploitation at its properties, including 26

27 17 PR Newswire, Red Roof and ECPAT-USA Launch Fundraising Campaign at the Hotel Industry’s AAHOACON 28 2922 Conference, (last visited April 15, 2025), https://www.prnewswire.com/news-releases/red-roof-and-ecpat- usa-launch-fundraising-campaign-at-the-hotel-industrys-aahoacon-2022-conference-301523022.html 1 at the Las Vegas location where Plaintiffs were trafficked. 2 61. Nationwide initiatives, such as the United Nations’ Blue Heart Campaign (1997)18 3 and the Department of Homeland Security’s Blue Campaign (2010)19, have acknowledged the 4 prevalence of human trafficking within the hotel industry and the absence of adequate internal 5 policies to address the issue. In response, these campaigns have aimed to educate both the public 6 and private sectors—including hotel businesses—by providing free resources to help the 7 hospitality industry combat human trafficking. 8 62. Widely recognized indicators of sex trafficking, which Defendants, and each of 9 them, were made of aware of, knew, or should have known, include but are not limited to: 10 a. Individuals show signs of fear, anxiety, tension, submission, and/or nervousness; 11 b. Individuals show signs of physical abuse, restraint, and/or confinement; 12 c. Individuals exhibit evidence of verbal threats, emotional abuse, and/or being 13 treated in a demeaning way; 14 d. Individuals show signs of malnourishment, poor hygiene, fatigue, sleep 15 deprivation, untreated illness, injuries, and/or unusual behavior; 16 e. Individuals lack freedom of movement or are constantly monitored; 17 f. Individuals avoid eye contact and interaction with others; 18 g. Individuals have no control or possession of money or ID; 19 h. Individuals dress inappropriately for their age, for the weather, or have lower 20 quality clothing compared to others in their party; 21 i. Individuals have few or no personal items – such as no luggage or other bags; 22 j. Individuals appear to be with significantly older “boyfriend” or in the company 23 of older males; 24 k. A group of girls appear to be traveling with an older female or male; 25

26 18 United Nations, The Blue Heart Campaign, (last visited April 15, 2025), 27 https://www.unodc.org/blueheart/#:~:text=The%20Blue%20Heart%20Campaign,help%20prevent%20this%20hein ous%20crime 28 19 Department of Homeland Security, DHS Blue Campaign Five Year Milestone, (last visited April 15, 2025), https://www.dhs.gov/archive/news/2015/07/22/dhs-blue-campaign-five-year-milestone 1 l. A group of males or females with identical tattoos in similar locations. This may 2 indicate “branding” by a trafficker; 3 m. Drug abuse or frequent use of “party drugs” including (but not limited to) GHB, 4 Rohypnol, Ketamine, MDMA (Ecstasy), Methamphetamines, Crack Cocaine, 5 Cocaine, and Marijuana; 6 n. Possession of bulk sexual paraphernalia such as attire, condoms, birth control, or 7 lubricant; 8 o. Possession or use of multiple cell phones; and 9 p. Possession or usage of large amounts of cash or pre-paid cards. 10 63. Upon information and belief, Defendants, and each of them, have access to 11 individual hotel location do-not-rent (hereinafter “DNR”) lists that often list reasons for the 12 refusal to rent, including suspicion of human trafficking. Defendants, and each of them, failed to 13 share this information across their branded properties or take proactive steps to prevent 14 trafficking. 15 64. Guest reviews on sites like TripAdvisor, Yelp, Google, and Expedia frequently 16 cite issues such as prostitution, physical violence, and criminal activity at the Las Vegas Red Roof 17 Inn. 18 65. Defendants, and each of them, monitored online reviews of the Las Vegas Red 19 Roof Inn, which, upon information and belief, provide substantial evidence of human trafficking, 20 violence, and other illicit activities occurring on the premises, such as: 21 a. A review from 2018 describes a pimp yelling and swearing at a prostitute about 22 which room to use while holding seven room keys, indicating multiple rooms were 23 being used for prostitution. 24 b. A review from 2017 calls the hotel a “hooker’s paradise,” describing prostitutes 25 yelling in hallways, men shouting, and a total absence of security. The guest, 26 unable to sleep, reported the disturbances to the front desk, only to be met with a 27 condescending smirk from the employee, who dismissively responded, “It’s 28 Vegas.” 1 c. A review from 2021 states that upon arriving at the hotel, the guest encountered a 2 person passed out on the sidewalk, witnessed a drug deal, and saw people hanging 3 over the balcony yelling, while others were sitting in cars smoking marijuana. 4 d. A review from 2021 details bloodstains left in a room. 5 e. A review from 2021 describes a dirty room with a comforter covered in burn 6 marks, while police actively arrested people at the hotel. 7 f. A 2016 review reports that a guest’s belongings were stolen after their door was 8 kicked in. The hotel stated they have no video surveillance. The guest noted, this 9 hotel does not value their customers safety and security. 10 g. Several reviews from 2018-2024 report fraudulent credit card charges, room 11 break-ins, and stolen property. 12 h. Several reviews spanning 2016-2024 report filthy conditions, including stained or 13 used towels, unclean rooms, unclean floors, and bug infestations. 14 i. Reviews from 2015-2024 complain of excessive noise, constant disturbances, and 15 heavy traffic due to the hotel’s proximity to an airport and a strip club. 16 66. Upon information and belief, these reviews, spanning nearly a decade, provide 17 clear evidence of human trafficking at the Las Vegas Red Roof Inn; this evidence was required 18 to be reported to the Red Roof Inn Defendants and, upon information and belief it was reported 19 and Defendants failed to address these issues and failed to intervene highlighting a disregard for 20 guest safety and a tolerance of sex trafficking. These examples demonstrate that the Defendants, 21 and each of them, knew or should have known of the problem and failed to take proactive 22 measures to not profit from it. 23 67. Evidence from other locations shows that Red Roof has consistently received 24 reports of widespread human trafficking at their branded properties, knew that the prevalence of 25 sex trafficking was an issue across its branded properties and failed to do anything to prevent 26 continuing to profit from it 27 68. The Red Roof Inn located at 1221 E. Dublin Granville Rd, Columbus, Ohio 43229 28 was officially declared a public nuisance and shut down for one year due to ongoing illegal 1 prostitution and rampant drug activity.20 2 69. Upon information and belief, The Woburn, Massachusetts Daily Times reported 3 as early as February 2000 that its Red Roof Inn was facing closure by the city licensing 4 commission as a result of pervasive criminal activity, prostitution and sex trafficking. Such 5 criminal activity persisted unchecked until at least 2012, when Joseph Maddux, Vice President of 6 Operations for Red Roof Inn, was compelled to appear before the Licensing Commission in 7 response to disturbing reports of dangerous men exploiting prostitutes as young as fourteen (14) 8 at the Woburn Red Roof Inn, along with 118 police reports from 2011 alone. In his testimony, 9 Maddux assured the Commission that Red Roof Inn's President and legal team had been informed 10 of the situation and outlined potential measures to address the ongoing criminal activity including 11 prostitution at its branded properties:21 12 a. Installation and prominent display of new security systems providing 24-hour 13 monitoring; 14 b. Institution of nation-wide changes to its registration policies and the information 15 obtained at check-in; 16 c. Increased physical security of the Red Roof Inn location; 17 d. Elimination of smoking floor(s); and 18 e. Hotel upgrades and price increases to price rooms beyond the criminal clientele. 19 70. However, there is no evidence that these measures were ever implemented either 20 at the Woburn location or nationwide. In July 2020, the Woburn License Commission once again 21 took action against the Red Roof Inn after over 150 police incident reports, including incidents of 22 human trafficking, prostitution, and drug activity.22 23 24 20 Justin Eddy, Esq, Partner at Tucker Ellis LLP, “Hotel Known for Drug Deals and Prostitution a Nuisance, Closed for One Year”, (last visited April 15, 2025), https://www.linkedin.com/pulse/hotel-known-drug-deals- 25 prostitution-nuisance-closed-one-justin-eddy; see also, State ex rel. Columbus City Attorney Richard C. Pfeiffer, Jr., v. Red Carpet Inn, et. al., No. 14AP-506,(M.C. No. 2014 EVH 60019), (last visited April 15, 2025), 26 https://www.supremecourt.ohio.gov/rod/docs/pdf/10/2015/2015-Ohio-4035.pdf 21 James Haggerty, Red Roof Inn Officials Vow to Cooperate, Daily Times Chronicle, (last visited April 15, 2025), 27 http://homenewshere.com/daily_times_chronicle/news/woburn/article_99cddca6-5983-11e1-8393- 0019bb2963f4.html 28 22 Woburn License Commission Regular Meeting City Council Chamber, (last visited April 15, 2025), https://woburnma.gov/wp-content/uploads/2020/08/7-23-20-License-Commission-minutes.pdf 1 71. Publicly available information, including news reports, reveals the long-standing 2 and consistent role of Red Roof in providing a venue for sex trafficking over the years. Among 3 the notable press coverage detailing the frequent use of Red Roof properties for illegal activities, 4 the following incidents were highlighted: 5 a. In 2010, a man and woman appeared in court on charges of trafficking a 14-year- 6 old Milwaukee girl at a Red Roof Inn in Oak Creek, Wisconsin. At the Red Roof 7 Inn, the traffickers gave the girl marijuana to smoke and then took pictures of her 8 naked, which were put on a local website.23 9 b. In 2010, two individuals were charged with transporting a minor for prostitution 10 after a 17-year-old runaway from California was trafficked at Red Roof Inn 11 locations in New York and Maryland.24 12 c. In 2012, a Pennsylvania man was indicted by a federal grand jury on sex 13 trafficking charges involving a 16-year-old girl trafficked at a New Jersey Red 14 Roof Inn in May of that year. He was sentenced to 10 years in federal prison in 15 2014.25 16 d. In 2012, a Minneapolis police officer investigating juvenile sex trafficking 17 discovered an ad on Backpage.com that featured a young woman offering 18 "unrushed service, full of pleasure." When the officer contacted the number on the 19 ad, they learned the woman was at the Red Roof Inn in Woodbury, Minnesota.26 20 21 22

23 23 John Diedrich, 2 face federal sex-trafficking charges, Milwaukee Journal Sentinel, (last visited April 15, 2025), 24 https://archive.jsonline.com/news/crime/96508359.html/ 24 Freeman Klopott, Teen Prostituted, Held Against Her Will in MD. and VA. Hotels, Feds Say, The Washington 25 Examiner, (last visited April 15, 2025), https://www.washingtonexaminer.com/teen-prostituted-held-against-her- will-in-md-and-va-hotels-feds-say 26 25 Michaelangelo Conte, Man Charged With Sex Trafficking a Teen He Met in Secaucus Takes Plea, NJ.com, (last visited April 15, 2025), https://www.nj.com/hudson/2014/03/man_originally_charged_with_sex_trafficking_a_16- 27 year-old_he_met_in_secaucus_takes_a_plea.html 26 Mike Longaecker, Police: Sex Trafficking Victim Turns Up at Woodbury Hotel, Republican Eagle, (last visited 28 April 15, 2025), https://www.republicaneagle.com/news/public_safety/police-sex-trafficking-victim-turns-up-at- woodbury- hotel/article_88eac778-73b4-50cb-ac65-182279d50948.html/ 1 e. In 2012, a Rochester, New York man and woman were charged in a sex trafficking 2 case involving a minor. Investigators found that two customers paid to have sex 3 with the victim, and the woman was arrested at the Red Roof Inn.27 4 f. In 2012 two teenage girls were trafficked at Red Roof Inn in Charlotte, North 5 Carolina. Investigations revealed that pimps would pay Red Roof Inn mangers and 6 maids to not report the illegal activities taking place. This situation led to Red Roof 7 Inn eventually pulling its brand from the hotel.28 8 g. In 2013, a 50-year-old man was charged with prostitution and human trafficking, 9 for forcing a woman to perform sex acts against her will at the Red Roof Inn on 10 Eisenhower Boulevard in Pennsylvania.29 11 h. In 2013, a Lubbock, Texas grand jury indicted four suspects arrested during a 12 prostitution sting at a Red Roof Inn.30 13 i. In 2013, the Knox County Sheriff's Office arrested a Knoxville, Tennessee man 14 for human trafficking at a Red Roof Inn.31 15 j. In 2014, a Cincinnati, Ohio man pled guilty in U.S. District Court to locking 16 women in his Avondale home and then driving them to a Red Roof Inn in 17 Louisville, Kentucky, where he forced them into prostitution.32 18 19 20 21 22 23 27 Department of Justice, ROCHESTER MAN AND WOMAN CHARGED IN SEX TRAFFICKING CASE, (last visited April 15, 2025), https://www.justice.gov/archive/usao/nyw/2012/TwoCharged.pdf 24 28 FBI investigating teen human trafficking at Charlotte hotel, WBTV3, (last visited April 15, 2025), https://www.wbtv.com/story/30058536/fbi-investigating-teen-human-trafficking-at-charlotte-hotel 25 29 Brittany Miller, Man charged in prostitution ring headed to Dauphin County court, Penn Live Patriot News (last visited April 15, 2025), https://www.pennlive.com/midstate/2013/10/post_625.html 26 30 4 Indicted on Prostitution Charges after Red Roof Inn sting, KCBD News 11, (last visited April 15, 2025), https://www.kcbd.com/story/23272377/4-charged-with-prostitution-offenses-after-red-roof-inn-sting/ 27 31 Knoxville Man Faces Human Trafficking Charges, End Slavery Tennesse, (last visited April 15, 2025), https://www.endslaverytn.org/news/knoxville-man-faces-human-trafficking-charges-newsarticle 28 32 Nathan Vicar, Avondale Man Pleads Guilty to Sex Trafficking in Louisville, Fox 19 Now, (last visited April 15, 2025), https://www.fox19.com/story/27390036/avondale-man-pleads-guilty-to-sex-trafficking-in-louisville/ 1 k. In 2014, a Rhode Island man pled guilty to attempted sex trafficking after being 2 accused of attempting to procure customers for sex with a 23-year-old woman at 3 a Red Roof Inn on Wolf Road in Albany, New York, on August 22, 2012.33 4 l. In 2014, a man was arrested by the FBI in Orlando, Florida for holding a 15-year- 5 old girl at a Phoenix, Arizona Red Roof Inn and selling her for sex. He was later 6 sentenced to eight years in prison.34 7 m. In 2014, a Mississippi man was arrested on human trafficking charges for 8 trafficking a 16-year-old girl from a Red Roof Inn in Madison County. He pled 9 guilty to the charges and was sentenced to 25 years in prison.35 10 n. In 2015, authorities arrested 15 men in a sex-with-minors sting at a Red Roof Inn 11 in Woodbury, Wisconsin. The investigation began in 2014 after a man was 12 apprehended at the hotel for responding to a Craigslist ad offering sex with a 32- 13 year-old woman, along with the and fondling of her deaf daughter.36 14 o. In 2016, two individuals were charged with human trafficking involving a minor 15 after their arrest at a Red Roof Inn in Louisville, Kentucky.37 16 p. In 2016, two individuals were charged in a human trafficking scheme after their 17 arrest at a Red Roof Inn in Jessup, Maryland.38 18 19 20 21 22 33 Dennis Yusko, Sex Traffic Case Ends in Plea, Times Union, (last visited April 15, 2025), https://www.timesunion.com/local/article/Sex-traffic-case-ends-in-plea-5440052.php 23 34 Jamee Lind, Phoenix Man Gets 8 Years for Selling Teen For Sex, The Republic, (last visited April 15, 2025), https://www.azcentral.com/story/news/local/phoenix/2015/03/30/phoenix-man-sex-trafficking-sentence- 24 abrk/70691190/ 35 Mary Grace Eppes, Man sentenced for human trafficking in Madison Co., WLBT3, (last visited April 15, 2025), 25 https://www.wlbt.com/story/27862158/man-sentenced-for-human-trafficking-in-madison-co/ 36 Mathias Baden, UPDATE: Police Arrest 15 Men in Sex-With-Minors Sting at Red Roof Inn, Republican Eagle, 26 (last visited April 15, 2025), https://www.republicaneagle.com/news/public_safety/update-police-arrest-15-men-in- sex-with-minors- sting-at-red-roof-inn/article_e48299f7-e13d-5c86-8e9f-f7faf22a8998.html 27 37 Charles Gazaway, 2 Charged with Human Trafficking Involving Juvenile, Wave 3, (last visited April 15, 2025), https://www.wave3.com/story/31910401/2-charged-with-human-trafficking-involving-juvenile 28 38 Saliqa Khan, 2 Men Charged in Howard County Human Trafficking Scheme, WBAL-TV 11, (last visited April 15, 2025), https://www.wbaltv.com/article/2-men-charged-in-howard-county-human-trafficking-scheme/7148473# 1 q. In 2016, two individuals were arrested in Lawrence, New Jersey, and accused of 2 running an interstate human trafficking ring out of a Red Roof Inn.39 3 r. In 2016, a man was sentenced to ten years in prison for trafficking a 15-year-old 4 girl at two motels, including a Red Roof Inn in Enfield, Connecticut.40 5 s. In 2016, two individuals were arrested on human trafficking charges for forcing a 6 woman into prostitution at a Red Roof Inn in Lafayette, Indiana.41 7 t. In 2016, a man was sentenced for human trafficking charges after forcing a woman 8 into prostitution at various hotels, including a Red Roof Inn in Newbury Port, 9 Massachusetts.42 10 u. In 2016, arrests were made following the investigation of a human trafficking 11 operation that was conducted out of several hotels, including a Red Roof Inn in 12 Joliet, Illinois.43 13 v. In 2017, a man was charged with sex trafficking at a Red Roof Inn in St. Louis, 14 Missouri.44 15 w. In 2017, six individuals were arrested following a prostitution bust at a Red Roof 16 Inn in Springfield Township, Ohio.45 17

18 39 Isaac Avilucea, New York Man Accused in Lawrence Sex Rings Boasts About $600K Manhattan Home, The 19 Trentonian, (last visited April 15, 2025), https://www.trentonian.com/2016/09/01/new-york-man-accused-in- lawrence-sex-rings-boasts-about-600k-manhattan-home/ 20 40 David Owens, Hartford Man Sentenced to Prison for Sex Trafficking of 15-Year-Old Girl, Hartford Courant, (last visited April 15, 2025), https://www.courant.com/2016/11/14/hartford-man-sentenced-to-prison-for-sex- 21 trafficking-of-15-year-old-girl/ 41 Joseph Paul, Suspected Pimps Charged With Human Trafficking, Lafayette Journal & Courier, (last visited April 22 15, 2025), https://www.jconline.com/story/news/crime/2016/12/29/court-docs-alleged-pimps-paid-victim- heroin/95952012/ 23 42 Julie Manganis, Man Gets 5 to 8 Years in Prison for Human Trafficking, Newbury Port News, (last visited April 15, 2025), https://www.newburyportnews.com/news/man-gets-5-to-8-years-in-prison-for-human- 24 trafficking/article_79f32b03-3e96-5360-af02-76c53e249dec.html 43 Felix Sarver, Joliet Hotel Among Meeting Places in Rappers‘ Sex Trafficking Ring, Shaw Local News Network, 25 (last visited April 15, 2025), https://www.shawlocal.com/2016/01/18/joliet-hotel-among-meeting-places-in- rappers-sex-trafficking- ring/alh59bo/ 26 44 Joel Currier, Man Charged With Sex Trafficking at Red Roof Inn in St. Louis, STL Today, (last visited April 15, 2025), https://www.stltoday.com/news/local/crime-and-courts/man-charged-with-sex-trafficking-at-red-roof-inn- 27 in-st- louis/article_4c70ac45-ac34-5d28-bd3c-92efde095381.html 45 Tara Molina, FBI Arrest Six at Springfield Township Red Roof Inn, News 5 Cleveland, (last visited April 15, 28 2025), https://www.news5cleveland.com/news/local-news/oh-summit/prostitution-bust-summit-co-investigators- fbi-arrest-six-at-springfield-township-red-roof-inn 1 x. In 2017, a human trafficking investigation led to the arrest of 23 individuals for 2 trafficking eight girls, ranging in age from 14 to 17, at multiple hotels in Stockton, 3 California, including the Red Roof Inn.46 4 y. In 2017, two church pastors were arrested for sex trafficking underage children, 5 including at a Red Roof Inn in Toledo, Ohio.47 6 z. In 2018, two men from Delaware were indicted on child sex trafficking charges 7 after a 15-year-old girl was found at a Red Roof Inn in Newark, Delaware.48 8 aa. In 2018, two individuals were charged for operating a sex trafficking ring out of a 9 Red Roof Inn in Urbana, Illinois.49 10 bb. In 2018, a local news station investigated a Florida Red Roof Inn because of the 11 high volume of search warrants that continued to pop up for the hotel, including 12 multiple warrants that reported a high volume of prostitution activity at the hotel.50 13 72. Several hundred traffickers and victims have been prosecuted by state and federal 14 law enforcement agencies for sex trafficking and forced prostitution at Red Roof-branded 15 properties. 16 73. Defendants were aware of the criminal activity and sex trafficking occurring at 17 Red Roof Inn properties across the Country. 18 74. Upon information and belief, Defendants’ upper-level executives monitored news 19 stories and law-enforcements reports on criminal activities and sex trafficking occurring at Red 20 Roof Inn properties across the country. 21 75. Upon information and belief, Defendants’ public relation department issued 22 23 46 Sarah Heise, 23 Arrested for Human Trafficking, Prostitution in San Joaquin County, KCRA, (last visited April 15, 2025), https://www.kcra.com/article/23-arrested-in-san-joaquin-county-human-trafficking/9588063 24 47 Justin Thompson-Gee, Two Pastors Arrested for Sex Trafficking Children, 58 News Milwaukee, (last visited April 15, 2025), https://www.cbs58.com/news/two-pastors-arrested-for-sex-trafficking-children 25 48 Richard Webster, Two Delaware Men Indicted on Charges of Child Sex Trafficking, Ace News Today, (last visited April 15, 2025), https://www.acenewstoday.com/two-delaware-men-indicted-on-charges-of-child-sex- 26 trafficking/ 49 Erick Payne, Two People Face Charges for Involvement in Trafficking Ring, WCIA, (last visited April 15, 27 2025), https://www.wcia.com/news/local-news/two-people-face-charges-for-involvement-in-trafficking-ring/ 50 Kylie McGlvern, Motel ‘Frequently Involved in Criminal activity‘ Sees More Than 200 Calls for service This 28 Year, ABC Action News, (last visited April 15, 2025), https://www.abcactionnews.com/news/motel-frequently- involved-in-criminal-activity-sees-more-than-200-calls-for-service-this-year 1 memorandums and communications regarding such criminal activities and sex trafficking 2 occurring at Red Roof Inn properties across the country. 3 76. Upon information and belief, Defendants began monitoring customer feedback, 4 including online reviews, in 2013 to look for instances of criminal activities and sex trafficking 5 occurring at Red Roof Inn properties across the country.51 6 77. Upon information and belief, the Red Roof Inn Defendants compiled reviews from 7 Reputology, an online aggregator, which provided feedback on locations nationwide, including 8 Las Vegas Red Roof Inn. The Red Roof Inn Defendants and Defendant Paradise required 9 employees to respond to reviews, particularly those that highlighted criminal activity or concerns 10 related to trafficking.52 11 78. Based on the accumulation of public information, news reports, and online 12 reviews, by the time Plaintiffs were trafficked at a Las Vegas Red Roof, Defendants, and each of 13 them knew, or should have known, that: 14 a. Sex trafficking was widespread and ongoing at Red Roof-branded properties, 15 including the Las Vegas Red Roof Inn; 16 b. Sex trafficking was a brand-wide problem for Defendants, originating from 17 management level decisions at their corporate offices; 18 c. Defendants failed to take reasonable steps to identify or address sex trafficking, 19 which was actively occurring at the Las Vegas Red Roof Inn; 20 d. Defendants’ efforts, if any, to stop trafficking were ineffective at the Las Vegas 21 Red Roof Inn; 22 e. Defendants were earning revenue by providing venues where widespread and 23 ongoing sex trafficking was occurring at the Las Vegas Red Roof Inn; 24 /// 25

26 51 Gary Stoller, Plugged In: Red Roof Inn Adds Electric Outlets, USA Today, (last visited April 15, 2025), 27 https://www.usatoday.com/story/travel/hotels/2013/04/05/red-roof-hotel-outlets/2056817/ 52 Use the New Hootsuite Reputology App to Monitor Online Reviews, E-Marketing Associates, (last visited April 28 15, 2025), https://www.e-marketingassociates.com/blog/use-the-new-hootsuite-reputology-app-to-monitor-online- reviews 1 f. Defendants were earning revenue by turning a blind eye to the human trafficking 2 occurring at the Las Vegas Red Roof Inn. 3 79. Upon information and belief, Defendants, and each of them, understood the greater 4 risks of prostitution and sex trafficking occurring in the Las Vegas area, due to its notoriety as a 5 hub for prostitution, and being located next to a strip club. 6 80. Upon information and belief, despite clear evidence that sex trafficking was 7 occurring at Las Vegas Red Roof Inn, Defendants, and each of them, continued to earn revenue 8 by continuing conduct that they knew or should have known would facilitate trafficking. 9 81. Upon information and belief, the Red Roof Inn Defendants exercise 10 comprehensive control over security and the reporting of criminal activities, including human 11 trafficking, across their properties. Upon information and belief, Red Roof implemented a policy 12 mandating staff at its branded locations, such as Las Vegas Red Roof, to report suspected criminal 13 activities to corporate oversight. Red Roof implemented these safety and security measures by 14 placing and monitoring security cameras, accepting and reviewing customer complaints, and 15 inspecting the Las Vegas Red Roof Inn. Red Roof also collected data regarding hotel operations 16 and customers, including names, payment information, reservation history, browsing data, and 17 other details associated with their stay. Given Red Roof’s retained control over security and 18 criminal activity reporting, it had the responsibility and ability to monitor and address signs of 19 illegal activities on their premises. Despite having the responsibility and the means to monitor 20 and address these reports through various security measures, such as camera surveillance and 21 customer data analysis, Red Roof failed to act on clear indicators of trafficking. This neglect 22 facilitated the sex trafficking of individuals, including Plaintiffs. 23 82. Upon information and belief, Red Roof Inn Defendants maintained control over 24 the safety and security measures at its branded properties by implementing systems that directed 25 customer complaints and reports of issues to Red Roof rather than the individual hotel locations, 26 including Las Vegas Red Roof. Despite establishing these reporting mechanisms, Red Roof failed 27 to take reasonable action in response to complaints of criminal activity and sex trafficking at its 28 branded properties, including Las Vegas Red Roof. 1 83. Upon information and belief, the Red Roof Inn Defendants retained control over 2 property-specific and customer data from Las Vegas Red Roof by dictating the methods for 3 recording, storing, and reporting this data. Through this control, Red Roof had actual or 4 constructive knowledge of the ongoing trafficking occurring at Las Vegas Red Roof during the 5 time Plaintiffs were trafficked there. Despite having access to detailed customer data, including 6 guest names, payment information, and reservation history, Red Roof continued to facilitate 7 trafficking at Las Vegas Red Roof by providing a venue and related services that enabled 8 traffickers to profit from sexual exploitation with minimal risk of detection or interference. 9 84. Upon information and belief, the Red Roof Inn Defendants knew or should have 10 known that its involvement in a venture with their branded properties, including Las Vegas Red 11 Roof, was in violation of 18 U.S.C. § 1591(a) by: 12 a. Upon information and belief, Red Roof Inn Defendants and Defendant Paradise 13 entered into a venture to operate Las Vegas Red Roof Inn, with the shared 14 objective of maximizing revenue and profits, while also sharing the risks 15 associated with the hotel operations; 16 b. Upon information and belief, Red Roof Inn Defendants knowingly received a 17 financial benefit from this venture in the form of franchising fees, royalty fees, and 18 other payments from Las Vegas Red Roof Inn; 19 c. Upon information and belief, Red Roof Inn Defendants violated 18 U.S.C. § 20 1591(a)(1) by participating in the venture through the management of Las Vegas 21 Red Roof and the acts and omissions of the staff at that location, thereby harboring 22 trafficking victims and enabling sex traffickers; 23 d. Upon information and belief, Red Roof Inn Defendants knew or, through the 24 exercise of reasonable diligence, should have known that it was engaging in 25 violations of 18 U.S.C. § 1591(a). Red Roof Inn Defendants should have been 26 aware of the trafficking activity at the Las Vegas Red Roof Inn, as it retained 27 control over key aspects of the hotel's operations and, therefore, had a 28 corresponding duty to act to prevent their profiting from the trafficking venture in 1 which it was participating. Despite this, Red Roof Inn Defendants continued to 2 knowingly benefit from their relationship with Las Vegas Red Roof Inn, including 3 the proceeds Red Roof obtained from the unlawful sex trafficking of Plaintiffs. 4 Even after becoming aware of these violations, Red Roof continued providing Las 5 Vegas Red Roof Inn with operational support, use of their trademarks, and other 6 resources to operate Las Vegas Red Roof Inn in a way that Defendants knew or 7 should have known was engaging in violations of 18 U.S.C § 1591(a). 8 e. Upon information and belief, Red Roof Inn Defendants knew, or should have 9 known through the exercise of reasonable diligence, that it was engaging in 10 violations of 18 U.S.C. § 1591(a). Red Roof retained control over relevant aspects 11 of the operations at Las Vegas Red Roof and thus had a duty to monitor and 12 address any illegal activity. Despite this responsibility, Red Roof continued to 13 benefit from its relationship with the Las Vegas Red Roof Inn, including financial 14 proceeds derived from unlawful sex trafficking. Even after becoming aware of 15 these violations, Red Roof continued to provide operational support, use of its 16 trademarks, and other resources to Las Vegas Red Roof, allowing it to operate in 17 a manner that violated 18 U.S.C. § 1591(a). 18 f. Upon information and belief, there were times when the Red Roof Defendants 19 obtained proof that they had profited from participating in a venture that violated 20 the TVPRA yet they did not disgorge themselves of the benefits they received. 21 THE SEX TRAFFICKING OF PLAINTIFF J.D. 22 85. Plaintiffs repeat and reallege each and every allegation contained above as though 23 fully set forth herein. 24 86. By means of a combination of force, coercion, physical abuse, threats, 25 manipulation, compelled use of and dependency on illegal substances, control over identification 26 documents and possessions, and deprivation of basic survival necessities such as, but not limited 27 to, food, water, transportation, shelter, and clothing, Plaintiff J.D.’s Traffickers forced her to have 28 commercial sex for money. 1 87. Plaintiff J.D.’s trafficking occurred when she was twenty-one (21), between 2016 2 through 2020, beginning in Oakland, California. J.D. was an aspiring model, and one of her 3 traffickers claimed he worked for a modeling agency. What initially appeared to be a promising 4 professional relationship quickly devolved into one of manipulation, abuse, and control. 5 88. Plaintiff J.D. had a number of Traffickers53, including one who has since been 6 arrested and charged for Human Trafficking in San Jose, California. 7 89. Soon after Plaintiff J.D.’s trafficking began, she was regularly trafficked in Las 8 Vegas, Nevada by a number of Traffickers, one of whom has since passed away. 9 90. During Plaintiff J.D.’s trafficking in Las Vegas, Plaintiff J.D. was coerced to 10 perform various sexual services at the Las Vegas Red Roof Inn. 11 91. Plaintiff J.D.’s traffickers rented rooms at the Las Vegas Red Roof Inn because 12 the location offered convenience, anonymity, and proximity to potential purchasers. At times, the 13 traffickers forced or coerced Plaintiff J.D. to go inside and rent the room herself, while they waited 14 nearby, often outside or just out of view, maintaining control over her and monitoring her actions. 15 92. Plaintiff J.D.’s traffickers found purchasers by advertising her on Skip The Games, 16 an internet site listing independent escorts and adult service providers, while connected to 17 Defendants’ internet. 18 93. During her stay at the Las Vegas Red Roof Inn, Plaintiff J.D. was held against her 19 will, forced to have sex with multiple purchaser’s every day and was raped on numerous 20 occasions. 21 94. During her stay at the Las Vegas Red Roof Inn, Plaintiff J.D. was repeatedly 22 physically abused. 23 95. Plaintiff J.D. was repeatedly tied up, punched, slapped, and beaten—not only with 24 fists, but also with household items, including the stick from the window blinds. At times, she 25 was so disoriented from the abuse that she could not recall when or how certain injuries occurred. 26 /// 27

28 53 Plaintiff will provide the names of the traffickers to Defendants once a protective order is in place. 1 J.D. carries the physical consequences to this day, including permanent facial scarring and lasting 2 internal damage, all from the repeated physical abuse she endured while trafficked. 3 96. During her stay at the Las Vegas Red Roof Inn, Plaintiff J.D. was subjected to 4 psychological torment, as her Traffickers withheld food and water, forced her to take illegal 5 substances, abused her, and threatened with death or severe harm for being disobedient. 6 97. J.D.’s traffickers maintained control through a relentless combination of violence, 7 manipulation, and surveillance—placing trackers on her and surrounding her with individuals 8 who monitored and reported her movements. The trauma has had lasting effects: including, J.D. 9 now struggles with trust, experiences difficulty with intimacy, and continues to suffer from the 10 psychological fallout of her exploitation. 11 98. During her stay at the Las Vegas Red Roof Inn, Plaintiff J.D. engaged with 12 numerous staff members of the Defendants, exhibiting multiple signs indicative of being under 13 the control of her Traffickers. These interactions presented clear indicators of human trafficking 14 that were easily recognizable. 15 99. J.D. recalls being severely disoriented, both mentally and physically, during 16 check-in and while staying at the Las Vegas Red Roof Inn. Despite these clear signs of distress, 17 staff members not only ignored her condition but also proceeded to rent her a room. They made 18 no effort to inquire about her well-being, contact law enforcement, or provide any assistance when 19 she was clearly in distress. 20 100. During her stay at the Las Vegas Red Roof Inn, Plaintiff J.D.’s Traffickers 21 implemented a methodical and well-established operational protocol, consistent with practices 22 widely recognized within the illicit sex trafficking industry, such as: 23 a. Plaintiff J.D.’s traffickers stayed at the Las Vegas Red Roof Inn in one-to-three- 24 day cycles over the trafficking period, encountering the same staff, within the 25 Trafficking Period. 26 b. An unusually high volume of individuals entered and exited Plaintiff J.D.’s room 27 at frequent intervals; 28 /// 1 c. Plaintiff J.D.’s Traffickers consistently refused housekeeping services, denying 2 hotel staff entry to the room; 3 d. Plaintiff J.D.’s room exhibited an excessive quantity of used illicit drugs, 4 prophylactics, soiled linens, and discarded clothing, indicative of commercial 5 sexual activity. 6 e. Plaintiff J.D. was consistently accompanied by her Traffickers when entering the 7 premises, displaying evident signs of distress, including evasive behavior, 8 reticence, and visible fear. 9 f. Audible disturbances, including loud vocalizations and screams, emanated from 10 Plaintiff J.D.’s room, suggestive of ongoing abuse and sexual assault. 11 g. Plaintiff J.D.’s Traffickers maintained possession and control of her legal 12 identification documents and passport, utilizing these for room reservations at the 13 Las Vegas Red Roof Inn. 14 h. Plaintiff J.D.’s Traffickers consistently utilized cash payments for room 15 reservations at the Las Vegas Red Roof Inn, a common practice in sex trafficking 16 operations; 17 i. Plaintiff J.D.’s Traffickers routinely requested accommodations in secluded areas 18 of the hotel, away from other guests; 19 j. Plaintiff J.D.’s Traffickers made frequent and excessive requests for fresh linens 20 and towels; 21 k. Plaintiff J.D. endured physical abuse in public areas of the Las Vegas Red Roof 22 Inn; 23 l. An unusually large quantity of used prophylactics was consistently observed in 24 Plaintiff J.D.’s Las Vegas Red Roof Inn room; 25 m. Plaintiff J.D.’s Traffickers repeatedly instructed hotel staff not to disturb the room 26 occupants; 27 n. Plaintiff J.D. was often observed wearing attire inappropriate for the prevailing 28 weather conditions; 1 o. Instances of loitering and solicitation were observed at Plaintiff J.D.’s Las Vegas 2 Red Roof Inn; 3 101. Consequently, Defendants knew or should have known of Plaintiff J.D.’s 4 trafficking at the Las Vegas Red Roof Inn, given the pervasive nature of sex trafficking indicators 5 in the case of J.D. and those within the hospitality industry about which Defendants knew 6 102. Despite the presence of numerous trafficking indicators that should have been 7 recognizable to trained hospitality staff, employees and/or agents of Defendants placed Plaintiff 8 J.D. in rooms isolated from other guests, further facilitating her exploitation. 9 103. These indicators of human trafficking were conspicuous and readily apparent to 10 any reasonably attentive employee at the Las Vegas Red Roof Inn. The prevalence and visibility 11 of these warning signs, which align with widely recognized indicators within the hospitality 12 industry, should have alerted properly trained staff to the ongoing exploitation at the Las Vegas 13 Red Roof Inn. 14 104. The failure to recognize and respond to these clear indicators of trafficking 15 demonstrates a severe lapse in the hotel's duty of to exercise reasonable diligence and care and 16 adherence to industry-standard practices for identifying human trafficking and halting Defendants 17 continued profiting from the trafficking venture. 18 THE SEX TRAFFICKING OF PLAINTIFF D.S. 19 105. Plaintiffs repeat and reallege each and every allegation contained above as though 20 fully set forth herein. 21 106. By means of a combination of force, coercion, physical abuse, threats, 22 manipulation, compelled use of and dependency on illegal substances, control over possessions, 23 and deprivation of basic survival necessities such as, but not limited to, food, water, 24 transportation, shelter, and clothing, Plaintiff D.S.’s Traffickers forced her to have commercial 25 sex for money. 26 107. Plaintiff D.S. was first trafficked at the age of twenty-three, between 2015 and 27 2018. She met her trafficker in Desert Hot Springs, California, through a friend of a friend. What 28 /// 1 initially appeared to be a friendly relationship quickly devolved into one of manipulation, abuse, 2 and control. 3 108. Soon after Plaintiff D.S.’s trafficking began, she was regularly trafficked in Las 4 Vegas, Nevada by a number of traffickers, one of whom has since passed away. 5 109. During Plaintiff D.S.’s trafficking in Las Vegas, Plaintiff D.S. was coerced to 6 perform various sexual services at the Las Vegas Red Roof Inn. 7 110. Plaintiff D.S.’s traffickers regularly rented rooms at the Las Vegas Red Roof Inn 8 due to its convenience, anonymity, and proximity to potential buyers. They frequently checked 9 in themselves and paid hotel staff to ignore the clear and obvious signs that D.S. was being 10 trafficked on the premises. The traffickers explicitly told D.S. that staff had been paid to look the 11 other way, using this information to further manipulate and control her. 12 111. Plaintiff D.S.’s traffickers found purchasers by advertising her on Skip The 13 Games, an internet site listing independent escorts and adult service providers, as well as 14 craigslist, while connected to Defendants’ internet. 15 112. During her stay at the Las Vegas Red Roof Inn, Plaintiff D.S. was held against her 16 will, forced to have sex with multiple purchaser’s every day and was raped on numerous 17 occasions. 18 113. While at the Las Vegas Red Roof Inn, Plaintiff D.S. was repeatedly beaten and 19 drugged by her traffickers. She often regained consciousness to find her legs being forcibly held 20 open as she was assaulted, before losing consciousness again. Her legs were frequently bruised 21 and scratched, and she was locked in the room for extended periods without any means of escape. 22 114. During her stay at the Las Vegas Red Roof Inn, Plaintiff D.S. was subjected to 23 psychological torment, as her traffickers withheld food and water, forced her to ingest 24 unidentified substances, and repeatedly threatened her with death or serious harm if she 25 disobeyed. The drugs left her disoriented and incapacitated, often causing her to black out for 26 extended periods, unable to comprehend or resist what was happening. She does not know what 27 substances were used—only that they were a method of control and subjugation. As a result of 28 /// 1 the prolonged and repeated drugging, D.S. now suffers from lasting cognitive impairments and 2 memory issues. 3 115. D.S.’s traffickers-maintained control through a relentless combination of violence, 4 manipulation, and fear. The trauma she endured has had profound and lasting effects. She now 5 struggles with trust, has difficulty with intimacy and forming relationships, and continues to suffer 6 from the psychological aftermath of her exploitation. D.S. also experiences ongoing fear for her 7 safety, often avoiding leaving her home due to a persistent sense that she could once again be 8 forced into trafficking. 9 116. During her stay at the Las Vegas Red Roof Inn, Plaintiff D.S. engaged with 10 numerous staff members of the Defendants, exhibiting multiple signs indicative of being under 11 the control of her Traffickers. These interactions presented clear indicators of human trafficking 12 that were easily recognizable. 13 117. D.S. recalls that while she was being trafficked at the Las Vegas Red Roof Inn, a 14 hotel cleaning staff member entered the room and witnessed her being physically beaten by her 15 trafficker. Rather than intervening or seeking help, the staff member turned around and continued 16 with her work. Staff members not only ignored D.S.’s condition but also made no effort to inquire 17 about her well-being, contact law enforcement, or provide any assistance when she was clearly 18 in distress. 19 118. D.S. further recalls, on multiple occasions, cleaning staff knocked on the door, 20 handed over towels, and walked away—despite observing multiple men entering and exiting the 21 room, numerous individuals inside at once, visible alcohol, drugs, and several used condoms in 22 plain view. These were obvious indicators that trafficking was occurring, yet staff members failed 23 to act. They ignored her condition and continued to provide service as if nothing was wrong. 24 119. During her stay at the Las Vegas Red Roof Inn, Plaintiff D.S.’s Traffickers 25 implemented a methodical and well-established operational protocol, consistent with practices 26 widely recognized within the illicit sex trafficking industry, such as: 27 /// 28 /// 1 a. Plaintiff D.S.’s traffickers stayed at the Las Vegas Red Roof Inn in one-to- 2 three-day cycles over the trafficking period, encountering the same staff, within 3 the Trafficking Period. 4 b. An unusually high volume of individuals entered and exited Plaintiff D.S.’s 5 room at frequent intervals; 6 c. Plaintiff D.S.’s traffickers generally declined full housekeeping services and 7 limited staff access to the room; however, on multiple occasions, cleaning staff 8 briefly entered to drop off towels and ignored clear indicators that Plaintiff D.S. 9 was being trafficked. 10 d. Plaintiff D.S.’s room exhibited an excessive quantity of used illicit drugs, 11 prophylactics, soiled linens, and discarded clothing, indicative of commercial 12 sexual activity. 13 e. Plaintiff D.S. was consistently accompanied by her Traffickers when entering 14 the premises, displaying evident signs of distress, including evasive behavior, 15 reticence, and visible fear. 16 f. Audible disturbances, including loud vocalizations and screams, emanated from 17 Plaintiff D.S.’s room, suggestive of ongoing abuse and sexual assault. 18 g. Plaintiff D.S.’s Traffickers consistently utilized cash payments for room 19 reservations at the Las Vegas Red Roof Inn, a common practice in sex 20 trafficking operations; 21 h. Plaintiff D.S.’s Traffickers routinely requested accommodations in secluded 22 areas of the hotel, away from other guests; 23 i. Plaintiff D.S.’s Traffickers made frequent and excessive requests for fresh 24 linens and towels; 25 j. Plaintiff D.S. endured physical abuse in public areas of the Las Vegas Red Roof 26 Inn; 27 k. An unusually large quantity of used prophylactics was consistently observed in 28 Plaintiff D.S.’s Las Vegas Red Roof Inn room; 1 l. Plaintiff D.S.’s Traffickers repeatedly instructed hotel staff not to disturb the 2 room occupants; 3 m. Plaintiff D.S. was often observed wearing attire inappropriate for the prevailing 4 weather conditions; 5 n. Instances of loitering and solicitation were observed at Plaintiff D.S.’s Las 6 Vegas Red Roof Inn; 7 120. Consequently, Defendants knew or should have known of Plaintiff D.S.’s 8 trafficking at the Las Vegas Red Roof Inn, given the pervasive nature of sex trafficking indicators 9 in the case of D.S. and those within the hospitality industry about which Defendants knew. 10 121. Despite the presence of numerous trafficking indicators that should have been 11 recognizable to trained hospitality staff, employees and/or agents of Defendants placed Plaintiff 12 D.S. in rooms isolated from other guests, further facilitating her exploitation. 13 122. These indicators of human trafficking were conspicuous and readily apparent to 14 any reasonably attentive employee at the Las Vegas Red Roof Inn. The prevalence and visibility 15 of these warning signs, which align with widely recognized indicators within the hospitality 16 industry, should have alerted properly trained staff to the ongoing exploitation at the Las Vegas 17 Red Roof Inn. 18 123. The failure to recognize and respond to these clear indicators of trafficking 19 demonstrates a severe lapse in the hotel's duty of to exercise reasonable diligence and care and 20 adherence to industry-standard practices for identifying human trafficking and halting Defendants 21 continued profiting from the trafficking venture. 22 DEFENDANTS KNOWINGLY ENABLED AND PROFITED FROM THE SEX 23 TRAFFICKING OF PLAINTIFFS 24 124. Plaintiffs repeat and reallege each and every allegation contained above as though 25 fully set forth herein. 26 125. Defendants played a direct and significant role in facilitating the trafficking of 27 Plaintiffs J.D. and D.S., at the Las Vegas Red Roof Inn. 28 126. Defendants knowingly benefited from the sex trafficking of Plaintiffs. 1 127. Defendants rented rooms to and provided internet to Plaintiffs' Traffickers when 2 they knew, or should have known, that human trafficking was prevalent within its branded 3 properties, including the Las Vegas Red Roof Inn. 4 128. Defendants benefited from the steady income generated by Plaintiffs’ Traffickers 5 and their purchasers. Defendants profited from every room rented by Traffickers and purchasers 6 where Plaintiffs were harbored for sex trafficking. 7 129. When Defendants were made aware of their profits from sex trafficking they did 8 nothing to disgorge themselves of the profits. 9 130. Defendants profited from the data it collected when Traffickers and purchasers 10 used the Las Vegas Red Roof Inns internet to advertise and solicit Plaintiffs for commercial sex. 11 131. Defendants’ employees, agents, and/or staff, particularly front desk employees, 12 knew or should have known of the obvious signs of Plaintiffs J.D. and D.S., trafficking at the Las 13 Vegas Red Roof Inn. 14 132. Given Defendants’ access to various sources of information, such as police reports, 15 news articles, complaints, prior convictions, and negative reviews regarding its properties, 16 Defendants knew or should have known of the trafficking occurring at the Las Vegas Red Roof 17 Inn, where Plaintiffs were trafficked. 18 133. Defendants knew or should have known of Plaintiffs’ trafficking occurring at the 19 Las Vegas Red Roof Inn, considering the city’s reputation for sex trafficking. 54 55 56 20 134. Defendants knew or should have known of Plaintiffs’ trafficking occurring at the 21 Las Vegas Red Roof Inn, due to the various clear signs of trafficking. 22 135. Defendants had multiple opportunities to stop the Traffickers who victimized 23 Plaintiffs J.D. and D.S., instead, Defendants failed to take reasonable measures to stop profiting 24 25 54 Jacquelyn Gray, Why Sex Trafficking is Such a Big Problem in Las Vegas, A&E, (last visited April 15, 2025), https://www.aetv.com/real-crime/sex-trafficking-in-las-vegas/ 26 55 Alyssa Bethencourt, Las Vegas is a hotspot for human trafficking, here’s how to spot signs, KTNV-13, ABC, (last visited April 15, 2025), https://www.ktnv.com/news/las-vegas-is-a-hotspot-for-human-trafficking-heres-how- 27 to-spot-signs/ 56 Stephanie Overton, Las Vegas police arrest more than 70 in sex trafficking operation during Grand Prix week, 28 Channel 8 News, CBS, (last visited April 15, 2025), https://8newsnow.com/news/local-news/las-vegas-police- arrest-more-than-70-in-sex-trafficking-operation-during-grand-prix-week/ 1 from the sex trafficking from at the Las Vegas Red Roof Inn. Red Roof's systematic willful 2 blindness to the situation enabled and encouraged sex trafficking, and they financially benefited 3 from the ongoing exploitation of Plaintiffs. 4 136. Defendants continued to enjoy financial gain from their reputation for privacy, 5 discretion, and their facilitation of commercial sex, knowing that these activities directly 6 contributed to the trafficking of Plaintiffs. 7 137. Defendants failed to take any meaningful steps to alert law enforcement, intervene 8 in situations involving Plaintiffs’ trafficking of which they knew or should have known, and failed 9 to implement reasonable security measures to identify and to prevent their profiting from the 10 human trafficking at the Las Vegas Red Roof Inn, including the sex trafficking of Plaintiffs. 11 138. Defendants maintained these deficiencies intentionally to maximize profits, 12 including by: 13 a. Reducing the cost of training employees, managers, and staff on how to identify 14 human trafficking and sexual exploitation, and what steps should be taken when 15 trafficking is suspected; 16 b. Failing to refuse room rentals or report guests to law enforcement, even when 17 such guests were identified as likely sex traffickers or purchasers of sex, in 18 order to maximize room occupancy and corresponding profits; 19 c. Cutting security costs by not employing qualified security personnel or 20 maintaining proper video surveillance systems to monitor and combat human 21 trafficking; 22 d. Failing to enforce proper policies and procedures to prevent and report human 23 trafficking, including not holding accountable hotel staff or managers who were 24 complicit in facilitating trafficking activities. 25 139. Despite having access to extensive information regarding sex trafficking indicators 26 and the conspicuous signs of Plaintiffs' exploitation at the Las Vegas Red Roof Inn, Defendants 27 failed to implement appropriate measures to intervene and prevent their profiting from the 28 trafficking of Plaintiffs. This inaction persisted despite widespread industry awareness of 1 trafficking risks, publicly available guidelines for prevention, and the presence of numerous red 2 flags that aligned with recognized indicators of human trafficking within the hospitality sector. 3 140. Defendants consistently failed to take necessary actions to prevent their profiting 4 from the exploitation occurring at the Las Vegas Red Roof Inn. Specifically, Defendants failed 5 to: 6 a. Mandate comprehensive training for employees and managers on identifying signs 7 of human trafficking and sexual exploitation; 8 b. Analyze data on criminal activity and customer reviews indicating trafficking at 9 their properties, and take corrective actions to address these issues; 10 c. Collect and utilize vast amounts of data from their locations for marketing 11 purposes but fail to apply the same data to combat trafficking in their hotels; 12 d. Refuse room rentals or report suspicious guests to law enforcement, prioritizing 13 maximum occupancy rates over the safety of trafficking victims; 14 e. Monitor and track guest wireless network activity for signs of illicit commercial 15 sex or human trafficking-related digital activity; 16 f. Implement adequate security measures, such as qualified security personnel and 17 appropriate cybersecurity, to combat trafficking and sexual exploitation; 18 g. Use their influence as a parent company to hold franchisees accountable for the 19 trafficking occurring on their properties. 20 141. Defendants’ deliberate failure to intervene and its ongoing facilitation of sex 21 trafficking at the Las Vegas Red Roof Inn directly enabled the continued victimization of 22 Plaintiffs and their continued profits from that victimization. 23 142. Defendants knew or should have known of the persistent sex trafficking occurring 24 within their establishments. Instead of implementing prompt and effective measures to combat 25 this crisis, they deliberately turn a blind eye to the blatant signs of exploitation. This willful 26 ignorance allows them to continue profiting from room rentals clearly used for illicit purposes. 27 By failing to address this issue, Defendants prioritize their financial gains over the safety and 28 /// 1 well-being of trafficking victims, effectively enabling the continuation of these criminal activities 2 on their premises. 3 143. As a result, Plaintiffs have suffered severe emotional distress, humiliation, mental 4 anguish, and physical pain and suffering, as well as a substantial loss of enjoyment of life. 5 Furthermore, Plaintiffs have incurred and will continue to incur medical expenses, attorney’s fees, 6 lost wages, diminished earning capacity, and punitive damages, all in an amount to be determined 7 at trial. 8 FIRST CLAIM FOR RELIEF 9 (Violations of 18 U.S.C. 1595 (“TVPRA”)) 10 Against all Defendants 11 144. Plaintiffs repeat and reallege each and every allegation contained above as though 12 fully set forth herein. 13 145. Plaintiffs J.D. and D.S., are victims of sex trafficking within the meaning of 18 14 U.S.C. § 1591(a) and are entitled to bring a civil action under 18 U.S.C. § 1595. 15 146. Defendants are liable under 18 U.S.C. § 1595(a) because in the ways described 16 above, Defendants knowingly or recklessly participated in harboring, maintenance, and/or other 17 acts in furtherance of sex trafficking, including the sex trafficking of Plaintiffs. Defendants, and 18 each of them, knowingly benefitted, by receiving financial and other compensation, through their 19 participation in a venture that they knew or were reckless in not knowing involved the trafficking, 20 harboring, and maintenance of sex trafficking victims in exchange for financial benefits. 21 147. Defendants’ acts, omissions, and commissions, taken separately and/or together, 22 outlined above, constitute a violation of 18 U.S.C. § 1595. Specifically, Defendants, and each of 23 them, had a statutory obligation not to benefit financially or receive anything of value from a 24 venture that they knew, or should have known, engaged in violating the TVPRA. At all relevant 25 times, Defendants, and each of them, failed to behave as reasonably diligent corporations and 26 breached this duty through their participation in the harboring, maintaining, soliciting, and 27 advertising Plaintiffs and their traffickers for the purpose of commercial sex induced by force, 28 fraud, or coercion. 1 148. Defendants knew or should have known of the persistent sex trafficking occurring 2 within their establishments. Instead of implementing prompt and effective measures to combat 3 this crisis, they deliberately turn a blind eye to the blatant signs of exploitation. This willful 4 ignorance allows them to continue profiting from room rentals clearly used for illicit purposes. 5 By failing to address this issue, the hotels prioritize their financial gains over the safety and well- 6 being of trafficking victims, effectively enabling the continuation of these criminal activities on 7 their premises. 8 149. Defendants, and each of them benefited as a result of these acts, omissions, and/or 9 commissions by renting rooms and providing internet/Wi-Fi to traffickers and customers, keeping 10 operating costs low, maintaining the loyal customer base that fuels the supply and demand of sex 11 trafficking, and limiting mandatory regulations. Moreover, on each occasion they received 12 payment for rooms, Defendants directly benefited from the sex trafficking of Plaintiffs when they 13 knew or should have known violations of §1591(a) were occurring. Defendants have never 14 disgorged themselves of the profit even though they admit they have profited from sex trafficking 15 in the Red Roof branded properties. 16 150. Defendants, and each of them, have participated in a hotel business venture and/or 17 a sex trafficking venture in which they knowingly benefited from the commercial sex trafficking 18 of Plaintiffs J.D. and D.S., who were trafficked as a direct result of Defendants' acts, omissions, 19 and/or commissions. In order to maintain the loyalty of the segment of their customer base 20 involved in the sex trade, Defendants continued renting rooms to traffickers, failing to intervene 21 despite obvious signs of trafficking. Defendants' failure to properly train and supervise their 22 agents and employees, coupled with their disregard for the welfare of their guests, enabled the 23 continued exploitation of Plaintiffs. The Red Roof Defendants, Paradise Defendant and 24 Plaintiffs’ traffickers engaged in a venture in which all were necessary parties to obtain the profits 25 from the sex trafficking of Plaintiffs. 26 151. Moreover, Defendants, and each of them, knowingly and directly benefited from 27 the sex trafficking of Plaintiffs J.D. and D.S., on each occasion they received payment for rooms 28 where Plaintiffs were sexually exploited by guests of the hotel. 1 152. Plaintiffs further allege that, as a result of the relationship between Red Roof Inn 2 Defendants and their branded properties, Red Roof Inn Defendants are vicariously liable for the 3 acts of their branded properties, including at Las Vegas Red Roof Inn. 4 153. Defendants’ conduct, as set forth above and with respect to this cause of action 5 was done with a conscious disregard for Plaintiffs' rights and safety, fully aware of the devastating 6 and probable consequences of their conduct. This conduct included the willful and deliberate 7 failure to act to prevent those consequences, justifying an award of punitive damages. 8 Specifically, despite Defendants’ knowledge of widespread sex trafficking occurring at the Las 9 Vegas Red Roof Inn, Defendants made the deliberate decision to continue profiting from the 10 exploitation of vulnerable individuals. Their failure to implement or enforce any meaningful 11 policies to prevent trafficking and the profits from trafficking, failure to train or supervise 12 employees, and complete indifference to the obvious signs of exploitation on their premises, 13 demonstrate a deliberate, reckless, and malicious disregard for Plaintiffs' well-being. Defendants 14 knew of the harm being caused, failed to take corrective action, and instead chose to perpetuate 15 the suffering of Plaintiffs for their own financial gain. This egregious and malicious conduct 16 justifies the imposition of punitive damages, as Defendants' actions were not only intentional but 17 meant to foster a system of exploitation. 18 154. Defendants’ conduct as set forth above, and with respect to this cause of action 19 exhibited implied malice towards Plaintiffs’ rights and safety. This conduct was despicable and 20 demonstrated a conscious disregard for Plaintiffs’ rights and safety, warranting an award of 21 punitive damages. Specifically, Defendants, and each of them, were fully aware, or should have 22 been fully aware, that sex trafficking was rampant at the Las Vegas Red Roof Inn, and yet they 23 chose to do nothing to prevent it. They ignored clear signs of trafficking, failed to intervene in the 24 face of overwhelming evidence, and continued to allow the exploitation of vulnerable individuals 25 to take place under their roof—all while reaping the financial rewards. This behavior, done with 26 malice and a total lack of concern for the human suffering occurring on their premises, warrants 27 the imposition of punitive damages to punish Defendants for their despicable conduct and deter 28 others from engaging in similar conduct in the future. 1 155. The conduct, actions, and omissions by Defendants, and each of them were 2 negligent, grossly negligent, intentional, willful, wanton, oppressive, malicious, and done with 3 conscious disregard to the rights and safety of Plaintiffs. 4 156. The totality of Defendants' actions and omissions demands punitive damages of a 5 magnitude sufficient to punish this egregious conduct and deter similar behavior across the 6 hospitality industry. The scale of these damages should reflect the prolonged nature of 7 Defendants’ misconduct, spanning years of inaction and willful ignorance, the severity of harm 8 inflicted on multiple victims due to Defendants’ failure to act, the substantial profits Defendants 9 repeated from the complicity in human trafficking, and the need to send a clear message to the 10 entire hospitality industry that such conduct will not be tolerated and will result in severe financial 11 consequences. 12 157. The necessity for exemplary punitive damages is further amplified by the unique 13 position of Las Vegas, Nevada in the hospitality industry. As the hospitality capital of the world, 14 Las Vegas sets standards and practices that reverberate throughout the global hospitality sector. 15 The high concentration of hotels and casinos in Las Vegas creates an environment where 16 unchecked trafficking can proliferate rapidly, magnifying the impact of corporate negligence. 17 Therefore, punitive damages must be of a magnitude that not only punishes Defendants but also 18 serves as a watershed moment for the entire hospitality industry, compelling immediate and 19 comprehensive reforms in Las Vegas that will set new global standards for combating sex 20 trafficking in hotels. 21 158. After escaping their traffickers, Plaintiffs J.D. and D.S., have spent significant time 22 and effort trying to rebuild their lives, which were violently torn away. The lasting trauma from 23 their captivity and abuse continues to affect them, serving as a constant reminder of the 24 Defendants' role in enabling their exploitation. 25 159. As a direct and proximate result of the acts or omissions of Defendants, and each 26 of them, Plaintiffs J.D. and D.S., have suffered severe emotional distress, humiliation, mental 27 anguish, psychological trauma, and physical pain and suffering, and a significant decrease in their 28 ability to enjoy life, all in excess of Fifteen Thousand Dollars ($15,000.00). 1 160. As a direct and proximate result of the acts or omissions of Defendants, and each 2 of them, Plaintiffs J.D. and D.S., have incurred medical expenses for the treatment of their injuries 3 and may require ongoing future treatments necessitated by the harm they suffered. The exact 4 amount of such past and future damages is unknown at this present time, but Plaintiffs allege that 5 they have suffered and/or will suffer damages in excess of Fifteen Thousand Dollars ($15,000.00). 6 161. As a direct and proximate result of the acts or omissions of Defendants, and each 7 of them, Plaintiffs J.D. and D.S., have suffered loss of income and/or loss of earning capacity, all 8 in excess of Fifteen Thousand Dollars ($15,000.00). 9 162. The actions and inactions of Defendants’, their officers, agents, servants, and 10 employees, directly and foreseeably caused Plaintiff to suffer these damages. Plaintiff is therefore 11 entitled to compensation for all such damages, including but not limited to past and future medical 12 expenses, therapy costs, lost enjoyment of life, and pain and suffering, in an amount to be proven 13 at trial. 14 163. As a direct and proximate result of the acts or omissions of Defendants, and each 15 of them, Plaintiffs J.D. and D.S., have had to retain the services of the law offices of CHRISTIAN 16 MORRIS TRIAL ATTORNEYS to pursue this action and are entitled to recover costs of suit and 17 reasonable attorney’s fees incurred herein. 18 TOLLING OF LIMITATIONS 19 164. To the extent that Defendants assert an affirmative defense of limitations, 20 Plaintiffs invoke the discovery rule. At the time they were harmed and through the end of their 21 trafficking, they were under the coercion and control of their traffickers who exercised coercive 22 control over them and severely restricted her freedom. As a result, Plaintiffs lacked the 23 information and capacity to understand their injuries and their legal causes. 24 165. At the time Plaintiffs were harmed, they did not know that they were the victims 25 of human trafficking as that term is defined by law, that their injuries arose from being 26 “trafficked” at Defendants’ hotel or that they were people “trafficked,” much less that they were 27 the “victims” of a legal venture and conspiracy involving Defendants, and they did not discover 28 and were not in a position to discover the legal cause of her injury until close to the time they 1 filed this case. 2 166. To the extent Defendants assert an affirmative defense of limitations, Plaintiffs 3 invoke the doctrine of equitable tolling because, as a result of being a victim of trafficking, 4 Plaintiffs faced extraordinary circumstances, which arose through no fault of their own, that 5 prevented them from filing a lawsuit. 6 176. While under the control of their traffickers Plaintiffs did not have the freedom to 7 investigate their claims, to identify those responsible, or to seek legal representation necessary to 8 pursue their legal rights. Plaintiffs could not have pursued their claims while under the active 9 control of their traffickers despite the exercise of ordinary diligence. 10 177. To the extent Defendants assert an affirmative defense of limitations, Plaintiffs 11 invoke the continuing violation doctrine because this lawsuit arises out of a pattern of continuous 12 and ongoing tortious conduct by Defendants, individually and in concert. 13 178. This continuous trafficking resulted from Defendants’ facilitation of trafficking at 14 the subject property and Defendants’ ongoing ventures with one another and with criminal 15 traffickers at the Red Roof Inn property at issue in this case. 16 WHEREFORE, PLAINTIFFS J.D. and D.S., pray for judgment against Defendants as 17 follows: 18 1. For general and special damages in excess of $75,000.00 for medical 19 expenses, pain and suffering, permanent injury, disfigurement, anguish 20 and afear, and lost wages. 21 2. For punitive damages; 22 3. For any and all pre- and post-judgment interest as permitted by law; 23 4. For reasonable attorney’s fees and costs; 24 5. For such other and further relief as the Court Deems proper. 25 /// 26 /// 27 /// 28 /// 1 DEMAND FOR JURY TRIAL 2 Pursuant to F.R.C.P. 38, Plaintiffs hereby demand trials by jury on all issues raised in 3 this action. 4 DATED this __ day of February 2026. 5 CHRISTIAN MORRIS TRIAL ATTORNEYS 6 /s/ Sarah E. DiSalvo

7 CHRISTIAN M. MORRIS, ESQ. 8 Nevada Bar No. 11218 SARAH E. DISALVO, ESQ. 9 Nevada Bar No. 16398 LINDSAY N. ROGINSKI, ESQ. 10 Nevada Bar No. 16616 11 2250 Corporate Circle, Suite 390 Henderson, Nevada 89074 12 Attorneys for Plaintiffs

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