The Tidal Wave of Lawsuits Facing Pornography Producers

It has been roughly one year since the case Jane Doe v. Cissy Steele et al. was filed, ushering in a wave of lawsuits against the exploitative pornography industry and turning the tide against the commercial sex industry overall.

Jane Doe v. Cissty Steele et al. has inspired a tidal wave of lawsuits against pornography producers, with more expected to come.

This civil case was jointly filed by the National Center on Sexual Exploitation Law Center, The Haba Law Firm, and DiCello Levitt Gutzler on behalf of a sex trafficking victim against her trafficker, as well as the pornography studios and websites that knowingly profited from her sex trafficking.

Since this case was filed last September, many more brave survivors of the abusive pornography industry have come forward, with as many as 8 cases filed against pornography websites and production studios and even more coming on the horizon. The fight against an industry built on exploitation and abuse is growing and moving swiftly forward.

We commend Jane Doe for her courage, her sacrifice, and her example in bringing this case to hold her exploiters accountable and prevent other women from suffering as she has. On this one-year anniversary, we want to remind you of what this case is about, give you a quick update on its progress, and drive home the importance of bringing these kinds of cases to court. Civil litigation is a long process, but there have been key updates that prove the case is moving forward, bringing hope to not only Jane Doe but the countless others just like her.

Jane Doe v. Cissy Steele Background

As the complaint reads, this all started when Jane Doe (Doe) was lured from her home with promises of a glamorous career as a model. Cissy Steele (Steele) portrayed herself as a legitimate modeling agent and recruited Doe by giving a business card to Doe, visiting Doe at Doe’s home, and promising to introduce Doe to a well-known fashion designer. Doe trusted Steele’s word and moved in with Steele, a move that Steele promised Doe would be life-changing for her aspiring career as a model and actress. For a few weeks Doe participated in some modeling photoshoots, giving her the illusion Steele was legitimate and that her career was taking off. Those photoshoots quickly stopped, and Steele began to mentally and physically abuse Doe.

Eventually, Steele did introduce Doe to her famous fashion designer friend, but instead of a glamorous networking connection, it was for the purpose of sex trafficking Doe. The fashion designer purchased Doe for commercial sex acts. All the money Doe received for those sex acts she was forced to give to Steele. This was unfortunately only the beginning, as Steele then began to traffic Doe in earnest. Doe was trafficked in Los Angeles, Las Vegas, and other areas of California. Like many traffickers, Steele coerced Doe with drugs and forced her to take ecstasy to keep her sexual performance high, even when her body was fatiguing. Doe was physically threatened into giving the money she was paid from these forced, coerced, and damaging trafficking sessions to Steele.

The abuse did not end with this trafficking and forced drug use. Steele also forced Doe to participate in pornographic film making. When Doe refused, Steele beat her, threatened her family, and even threatened to kill Doe’s dog. Doe performed in the pornographic films as coerced, but was never paid. Any money derived from the illicit venture was paid to Steele. After Doe finally was able to escape Steele, the trafficker then proceeded to harass and threaten Doe’s family, demanding Doe’s return.

The pornography production studios and websites involved in Doe’s trafficking continued to immortalize her horrific experiences. Even after her escape from her trafficker, a number of pornography studios and websites bought and/or pirated abuse content of Jane Doe and in some cases, continued to distribute it online even after Jane Doe requested removal.

Case Updates

Since originally filing her case on September 15, 2020, the case has slowly progressed. There have been two significant milestones.

First, Jane Doe filed a motion to proceed anonymously.

This is how a survivor can ask the Court to proceed as a “Jane Doe” rather than using the survivor’s legal name, for her privacy and protection. This usually comes with a protective order to outline the parameters of keeping Jane Doe’s information confidential, when and how to share it with the Defendants, and sets restrictions on if, when, and how Defendants can share her information with potential witnesses for questioning etc. This is standard in cases of alleged sexual abuse and sex trafficking.

However, some of the Defendants, Diabolic video Productions, Black Ice LTD, and Third Degree Films, actually opposed Jane Doe’s motion claiming it would unfairly prejudice them. Thankfully, the Court did not buy this argument and granted Jane Doe’s motion to proceed anonymously. Later, the parties came to an agreement as to a joint protective order to keep Defendants confidential trade secrets and other competitive business information confidential and also to protect Jane Doe’s private personal and identifying Information.

This is a hugely significant milestone that cannot be understated, as it protects Jane Doe’s identity and personal information, giving a survivor control of a narrative she did not have for the duration of her abuse at the hands of her traffickers and pornography companies.

Second, most of the Defendants have filed answers to Jane Doe’s allegations.

Defendant Steele denies all allegations, except that she self-identifies as Miss Madame and Bosslady on social media. Since plaintiff is filing anonymously, Steele claims that she is unable to respond with accurate knowledge to the facts alleged; therefore, she denies them. The pornography filming businesses also deny all the allegations. They allege that due to Doe’s anonymity, they are unable to accurately respond to the complaint.

Despite their denials, we have confidence the case will continue to progress. Clearly this case has a long way to go, but we applaud the Judge for ruling in favor of Jane Doe’s motion to proceed anonymously and we will keep you updated.

We won’t stop until the traffickers, abusive pornography business, and the commercial sex industry itself is held accountable for the untold harm and exploitation they have caused.

If you are interested in keeping up with this case or reading more about the National Center on Sexual Exploitation’s legal work, visit our page here.

The Numbers


NCOSE leads the Coalition to End Sexual Exploitation with over 300 member organizations.


The National Center on Sexual Exploitation has had over 100 policy victories since 2010. Each victory promotes human dignity above exploitation.


NCOSE’s activism campaigns and victories have made headlines around the globe. Averaging 93 mentions per week by media outlets and shows such as Today, CNN, The New York Times, BBC News, USA Today, Fox News and more.



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