The National Center on Sexual Exploitation filed a lawsuit in the United States District Court for the Northern District of California, San Jose Division. Co-counsel are Kim Adams (Levin Papantonio), Christopher Paulos (Levin Papantonio), Kathryn Avila (Levin Papantonio), and Eric Bauer.  The plaintiff, B.M., was 16 years old when her trafficking began at the Defendant hotels in 2014. Defendants are Wyndham Hotels and Resorts, Inc., Choice Hotels International, Inc. and G6 Hospitality, LLC.

B.M. was trafficked throughout Santa Clara County, California at Super 8 (Wyndham Hotels and Resorts, Inc.), Clarion Inn (Choice Hotels International, Inc.), and Motel 6 (G6 Hospitality, LLC). For two years, Plaintiff’s traffickers rented two adjoining rooms at the Super 8 and Clarion Inn. Plaintiff was one of several other girls that were being simultaneously trafficked in these two rooms. Each girl, including minor Plaintiff B.M., would be forced to perform commercial sex acts with ten to fifteen men a day.

Clarion Inn employees threatened to eject Plaintiff B.M. and her traffickers, but never took further action. Despite these threats, Plaintiff B.M. and several other victims continued to be trafficked on the premises.

For one month, Plaintiff B.M. was trafficked at the Motel 6, where she was raped hundreds of times for the profit of her pimp and to the benefit of Defendant G6. Plaintiff was forced to perform commercial sex acts with up to twenty (20) men a day.

Day after day, a procession of adult men would enter minor Plaintiff B.M.’s room, stay for 15 minutes to an hour on average, and then leave.  One of Plaintiff’s traffickers had a personal relationship with the front desk employee at the Motel 6. Through this relationship, Plaintiff’s trafficker was able to secure a room in the back of the hotel, out of sight from most of the other patrons and passerby. This front desk employee would also notify the trafficker when law enforcement officials were on or near the premises.

Through hotel staff and employees, Defendants knew or should have known that Plaintiff B.M. was being trafficked for sex due to, but not limited to:

1. large amounts of used condoms, empty lube bottles, and other sex-related items in the hotel room; payments for the rooms in cash;
2. Plaintiff’s physical appearance (malnourished, bruised, beaten)
3. a continuous procession of older men entering and leaving minor Plaintiff B.M.’s room;
4. excessive requests for sheets, cleaning supplies, room service
5. the personal relationship between the front desk employees and Plaintiff’s traffickers

The Defendant Hotels all financially benefited from the sex trafficking of B.M., and other victims like her, and developed and maintained business models that attract and foster the commercial sex market for traffickers and buyers alike.

Defendant Hotels enjoy the steady stream of income that sex traffickers bring to their hotel brands, such as the Super 8, Clarion Inn, and Motel 6.

Defendant Hotels financially benefit from their ongoing reputation for privacy, discretion, and the facilitation of commercial sex.

Defendant Hotels failed to take any steps to alert the authorities, properly intervene in the situation, or take reasonable security steps to improve awareness of sex trafficking and/or prevent sexual exploitation on their properties.

Defendant Hotels maintained their deficiencies to maximize profits by:

• Reducing the cost of training employees and managers on how to spot the signs of human trafficking and sexual exploitation and what steps to take;
• Not refusing room rentals, or reporting guests to law enforcement, in order to maximize the number of rooms occupied and the corresponding rates, even if the rooms rented were to sex traffickers or buyers;
• Lowering security costs by not having proper security measures, including, but not limited to, employing qualified security officers to actively combat human trafficking and sexual exploitation.

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