Human Trafficking with Babin Law

By Susan Barfield
June 24, 2022

Susan Barfield (00:05):
Hello everyone, thank you for joining another Case Works stream. We are honored today to be joined by two attorneys from Babin Law Firm. We’ve got both Steve Babin, and we have Kristina Aiad-Toss. Today, we are going to be talking about human trafficking. So, thank you both for joining us today, sharing insights into this litigation, and as I mentioned prior to starting the recording, it’s just not enough information in the industry. So, we appreciate you guys coming on as experts to not only provide this information, but so that we can share it to other attorneys in the industry. So, thank you both.

Dan Comunale (00:46):

Steven Babin (00:48):
Thanks for having us here.

Susan Barfield (00:49):

Dan Comunale (00:51):
All right, thank you so very much, Susan. For some of our newer reviewers, I just want to thank Susan Barfield, our Founder and Chairperson here at Case Works. She founded the company and has grown it to where it is today. So, thanks so much, Susan, for the intro.

Dan Comunale (01:06):
For our viewers as well, I want to introduce Steve Babin. All around great guy. He’s Managing Partner at Babin Law. He’s the managing partner. He’s a highly respected attorney in the mass tort space. He’s on numerous leadership positions across numerous MDLs, including Bard. He has a leadership position in Boy Scouts of America, the Leadership Coalition. He is on leadership in Valsartan. But we are primarily here to talk about his role in the human trafficking litigation.

Dan Comunale (01:36):
He filed the first standalone case, I believe, Steve, right, in the country against hotels under the Federal Trafficking Victims Protection Reauthorization Act. Later, Steve will describe what that is in context of litigation. He represents numerous human trafficking clients across the nation. He really holds hotels accountable for turning a blind eye to this horrific crime. He is one of the preeminent attorneys in leading the charge in holding all parties accountable for their role, or lack of, stepping in on this litigation. So, paving this path forward.

Dan Comunale (02:18):
Steve, thank you so much for everything. We’d love to hear to more about the specifics later. Kristina is currently an associate attorney here at Babin Law representing human trafficking survivors. Kristina serves a board member for the SOAP Project, and Kristina maybe a little later you can dive into what that exactly is. It’s a national ant-human trafficking nonprofit. It has a history [inaudible 00:02:44] various nonprofits fighting both sex trafficking and forced labor. We’ll get into what led you into this litigation, why you’re so passionate about it, and very excited to hear from the both of you.

Dan Comunale (02:55):
So, without further ado, we’ll jump into the meat of the presentation. Today obviously we are here to discuss the massively important yet disturbing and sensitive case of human trafficking. Many survivors of human trafficking face a lifetime of trauma. Thanks to lawyers like Steve, and Kristen, and others in the litigation, they’re able to have a venue, a voice, and be heard so that they can seek the justice they severely deserve. We’re grateful for the both of you. We’re grateful for the Babin Law Firm. We know you work with many tremendous lawyers in the space, some of the biggest names in the industry that you’re collaborating with to hold the hotels and the various defendants accountable.

Dan Comunale (03:40):
We’re thankful. We’re grateful. We’d love to hear a little bit of background and how you guys got into this litigation, case updates, and any lawyers out there that are looking to get involved, how they can get involved if they have some retained clients, what they can do. We’d just love to hear more about this.

Dan Comunale (04:01):
Steve, before we get into details of the human trafficking cases, what initially caused you to become of the premier advocates and vocal leaders in this litigation?

Steven Babin (04:10):
Dan, thank you for the kind introduction. I know that you have probably seen me in more rare form some trips too. Just like anybody, I went to law school because I wanted to change the world and to help people. I ended up doing mass tort work, which is great work. It’s one to make a difference in people’s lives. But this case really had a lot of the things that I wanted to do with my life, and my core values aligned with this case.

Steven Babin (04:40):
This case has significant justice issues. It has issues where the least of them, and the least powerful people on the outside of society are being taken advantage of. There are big corporate dollar players involved in this case who know what’s happening, they’ve known what’s happening for decades. They don’t do anything about it. They continue to put profits over people over, and over, and over again. 99% of the trafficking in the country occurs in hotels and motels. It’s a safe haven for criminal activity.

Steven Babin (05:14):
No one had done it yet, really, so all the law is new. From just a purely academic standpoint, you get to be creative. It’s not a picture that’s already been painted, or a paint-by-numbers. It’s our own masterpiece here where we get to make arguments that haven’t been made, we get to develop new law, we get to work with really smart lawyers across the country who are also involved heavily in these cases. We want to do that. At the end of the day, we get to hold people accountable and hopefully get some modicum of justice for our clients.

Susan Barfield (05:47):
Thanks, Steve. Moving into learning a little bit more about the background of this case, can you tell us a little bit about the Trafficking Victims Protection Reauthorization Act of 2003?

Steven Babin (06:00):
Sure, I’m going to give this one to Kristina, I think.

Susan Barfield (06:01):

Kristina Aiad-Toss (06:04):
Yeah, happy to jump in. The Trafficking Victims Protection Reauthorization Act actually started just as the Trafficking Victims Protection Act, the TVPA, was originally passed in the year 2000. It’s been reauthorized multiple times. It’s basically the end-all-be-all legislation that the US government passed deciding it wanted to dedicate a lot of attention to the issue of human trafficking both in the sex trafficking and forced labor context. It established a lot of federal attention and resources on this issue, and did things like mandate the annual Trafficking Persons Report that the Department of State and other government agencies put out every year.

Kristina Aiad-Toss (06:44):
In 2003, that’s when we first saw a civil right of action be authorized into the statute, which allowed human trafficking survivors to be able to sue their traffickers. Then in 2008, the reauthorization of the TVPA, that’s what led to the third party beneficiary prong, which is what the human trafficking hotel litigation is brought under. It allows to sue anyone who knowingly benefits from what they knew or should have known was a trafficking venture, and this really gives you the ability to sue anyone who benefits, corporations being obviously what we do.

Kristina Aiad-Toss (07:22):
So, that allows you to hold hotels accountable, and other entities such as tech companies, that benefit from the venture of human trafficking when they knew or should have known it was happening.

Dan Comunale (07:35):
Gotcha. That makes a lot of sense. Steve or Kristina, from a negligence standpoint what must a plaintiff plead during a lawsuit in order to provide a basis for the defendants being held negligent? Can you also speak to some details surrounding negligence in these types of cases, which is obviously very important for the overall case?

Steven Babin (07:58):
Sure, I can speak to that. Just to kind of put your question into context, the statute itself has a negligence standard. It’s a federal statute with a negligence-esque standard. You certainly could plead a negligence claim here too if you’re within the Statute of Limitations. These claims, under the federal statute, have a 10 year Statute of Limitations, which is nice. It gives you some time to develop the case, which these days are pretty complex, and we need that time.

Steven Babin (08:27):
As far as the negligence standard as applied within the context of the TVPRA, essentially the theory of liability goes as such, hotels and motels at the very highest corporate level know that human trafficking is a problem in the hospitality industry. Certainly, if they were to open their eyes they would know it’s an issue on their properties. They would see cops coming and arresting people for trafficking. They would see reports in the newspaper. They would see complaints from hotel visitors and guests, and whatnot.

Steven Babin (09:02):
As a result of having that information at their fingertips, what they should have done is implemented policies and procedures across their hotels with respect to what to do when human trafficking or suspected human trafficking is occurring on their premises. They did not. Across the board, they did nothing. What they did was signed on to some agreement with a nonprofit agency that said, “Hey, we’re really going to do some stuff to change the world here,” but when giant corporations like a Wyndham Hotel held training, they had a handful of people show up for those trainings, 10 or 15 people to a training across the whole corporation.

Steven Babin (09:41):
Then the idea here is having implemented these policies and procedures, they would have been able to know what was going on with our clients and their circumstances, and situations. We don’t have to prove under the federal statute that the corporation’s negligence caused the injuries. We just have to prove that they should have known. Then it’s essentially a strict liability application from there. In my read of the statute.

Steven Babin (10:07):
Now, this hasn’t been briefed yet, but my read of the statute is, if you can get that “should have known standard”, the causation isn’t necessary like it would be in a regular pharmaceutical case or whatever. Its strict liability. If you benefit… That’s what they have to do first, they have to benefit. They’re already doing that. They’re profiting millions and millions of dollars [inaudible 00:10:26] traffickers. If you benefit from what you knew or should have known with trafficking, you’re liable. Period. End of the story. That’s what the statute says.

Steven Babin (10:35):
So, how do we prove that? How do we prove that they should have known? With respect to specific policies, there are a number of accepted red flags of human trafficking in the industry, and in the hotel and motel industry. Kristina, I don’t know if you have some at your fingertips or maybe in your brain, but maybe you can share some of them as they come to your mind, red flags of human trafficking in the hotel industry.

Kristina Aiad-Toss (11:01):
A few that come to mind are things like the foot traffic coming in and out of the hotel, excessive requests for new towels and linens, check paying for their hotel room in cash, a victim showing signs of abuse and trauma, like bruising and visual signs like that, that the front desk would be seeing. Those are just a few of the examples that a lot of international nonprofits, and the Department of Homeland Security has identified for a number of years now.

Steven Babin (11:34):
I just want to put this into context too, because I get pushback sometimes even when I talk to other lawyers, that are like, “How could you know? How could you know?” But if you put this into context and think about it, if Dan or me walk into a hotel with seven young women that are in their early 20s, first of all that’s weird already. Then they’re paying for rooms in cash. They’re asking for rooms by exit doors. The pimp is standing in the hallway as people go in and out.

Steven Babin (12:01):
But even the check-in itself has got so many suspicious red flags that pop up. I don’t think I’ve ever been in a situation where I’m with six or seven young women going anywhere. So, I think that when you actually think about on the ground what you’d be seeing, it’s pretty easy to spot.

Dan Comunale (12:24):
Right. Steve, you mentioned a little bit about training surrounding it. If this is not a question you want to answer here, has there in any of the discovery up to this point been anything surrounding training to point out these red flags to your knowledge? Or if you want to next question it, that’s fine as well.

Steven Babin (12:45):
No, I mean, look, we’ve taken a lot of depositions. There are documents that talk about training, like “Maybe we should train.” There are proposals from nonprofits to train employees. With respect to actual training, there is such a limited amount of training that occurred, it’s sort of unbelievable. With respect to policies and procedures that would be implemented as a result of that training, or just implemented in general and to be trained on those, those are sort of nonexistent as well.

Steven Babin (13:17):
So, you could take maybe a human trafficking training, which… When I say very limited, I mean less than 5%, way less really, are getting trained. It’s not as if there’s a Human Trafficking Policy and Procedure implemented, and you have to adhere to that as an employee no matter what, but you can get trained on it. The fact is, you could get trained if you wanted to, but you probably won’t. And there is no policy or procedure with respect to trafficking that’s implemented across the hotel brand.

Susan Barfield (13:47):
The things that you’re mentioning just seem like common sense, like you don’t really need training to just have a gut instinct that something’s just not right.

Steven Babin (13:57):
It’s a PR issue for I think… It’s a profits over PR issue, but it’s a PR issue and it’s a sort of double expense issue because what you’re asking the hotel industry to do, which they have never done, is one, admit that you have a problem on your properties, not in the hospitality industry itself. Then once you do that, to turn down millions of dollars worth of business, and to spend millions of dollars worth of money to train your people and to implement policies and procedures. So, it’s a sort of double money pit for them that I just think they’ve avoided falling into until now.

Susan Barfield (14:29):
Mm-hmm (affirmative), yeah. Kristina or Steve, would you share a little bit about the RICO Act of 1970, and potentially how that impacts the legal strategy of the human trafficking cases that you’re working on?

Kristina Aiad-Toss (14:46):
Yes, I’m happy to touch on that for you, please. The TVPRA actually added human trafficking as a racketeering offense under RICO. The TVPRA actually makes human trafficking a tangible offense under RICO both for criminal claims and civil claims. We’ve seen a lot of the human trafficking cases bring corresponding RICO claims with different success rates. So, under RICO it’s typically a bit of a higher standard of proof because you’re proving that the entities were involved in an enterprise versus a venture. So, it requires a lot of times a higher pleading of facts, more detailed allegations, and that kind of thing.

Kristina Aiad-Toss (15:30):
We’ve some struck down based on those principles. There’s also considerations with the shorter Statute of Limitations, and also in respect to getting personal injury damage. There’s really been just mixed decisions in the court among this. This is something at Babin Law we’ve looked into and considered, and it’s not something that we’re currently bringing with a lot of our cases. It’s also a bigger instance among state court decisions, and RICO statutes vary from state to state, so you’ll get varying standards of proof, varying pleading requirements, and varying SOLs.

Steven Babin (16:06):
I’ll jump in real quick too. We’re not opposed filing a RICO claim necessarily. It does have a heightened pleading standard. I’m not a RICO practitioner, but for anybody whose never filed a RICO case, you’re going to get some serious scrutiny on your complaint at the Rule 12 Motion stage of the case. Right now, we’re really trying to develop a good complaint for the TVPRA claim itself. Certainly, we have explored RICO a lot, and I’m not saying that we won’t pivot to adding a RICO claim for it. We’re just not there yet.

Dan Comunale (16:39):

Susan Barfield (16:40):

Dan Comunale (16:41):
Speaking of some of the claims, what about the potential civil conspiracy claims, and to put it in a little context for our audience who might be unfamiliar, you can kind of speak about what that is, the claims against the hotel defendants, website owners, and the basis of those claims as well.

Steven Babin (17:00):
Yes, I think the civil conspiracy claim is fairly strong. Let me give you the 30,000 foot overview of what it is that we’ve been pleading, and then what it does to potentially actually open up a better RICO claim as well. The concept here is that the hotel industry as a whole failed to address human trafficking, and they did so vis a vis their trade associations. So, the American Hotel and Lodging Association, for example. Essentially what they did is they talked a lot about trafficking being an issue, but they together failed to implement any policies or procedures that would be required to be adhered to.

Steven Babin (17:43):
Even when we filed these cases back in 2019, the first round of them, the AHLA and a lot of the underlying state hotel and lodging associations let out this “No Trafficking Room Left B Behind” or something campaign, which was clearly a reaction to the litigation that was coming forward. It just looks nice on a pamphlet. So, our conspiracy claim is, these guys got together and they decided not to do anything because it’s incredibly expensive probably to do something about it.

Steven Babin (18:19):
I don’t know if this is the right time, but are we going to touch on the interaction between the property owners and the [inaudible 00:18:26]?

Susan Barfield (18:25):
Yeah, let’s talk about it.

Steven Babin (18:29):
That’s not necessarily a conspiracy claim, and if you want to stick a question in there maybe you can. Another issue that has come with respect who are the parties in the hotel cases and what are their interactions amongst each other, the corporate hotels, if you see a Wyndham, or a Hilton, or an IHG of your choice, they’re going to say, “These are franchise hotels. It’s not our responsibility.” Our position is, first of all that’s [inaudible 00:18:59] basically. You guys have so much [inaudible 00:19:01] these properties to say that you couldn’t do anything is ridiculous.

Steven Babin (19:05):
You come in and you audit these places to make sure they comply with your brand standards, and your brand standards [inaudible 00:19:13] things like the nth degree. You can get Bob Frank’s creamer, but if you get creamer from Bob Evans, they’ll demerit you, they’ll make you pay a fine, they’ll make you get training on the proper and appropriate creamer vendor. All of that. Literally, we have a case where this person got dinged for creamer three times in a row, and I had to pay a fine or do some kind of demerit, right? But they can’t implement policies and procedures with respect to human trafficking? That’s bogus.

Steven Babin (19:40):
The other thing that’s bogus too, is the franchisee owners certainly can’t, on their own, unilaterally implement policies and procedures. That’s the entire point of buying a system. They’re buying a system. They’re buying a process. They’re buying a brand. That brand is supposed to have a reputation behind it. It’s the brand’s responsibility to implement those things and to protects its reputation. I think that what it is, because this is a discussion we have a lot, should we sue the local property? It’s all the same instruments policy generally. It’s the local properties insurance policy, and it covers the brand.

Steven Babin (20:16):
My position is, it’s pretty much impossible to sue all of the local properties, and to od this in any kind of group or mass litigation. If you get involved, you’ll find very quickly that there are thousands of cases out there. You’re going to get one, and it’s going to quickly turn into many, many, many more cases because this is a tight group of people once they’re out. It happens all over the place, much more than you would like to believe. To get some kind of justice, I think you have to go out there to brands and related brands.

Steven Babin (20:46):
There are other strategies where we’re dealing with respect to their local property areas, but at the end of the day they’re also agents. They’re going to say, “These guys weren’t our employees,” although on their website they say, “They’re our employees.” They identify them as employees. They pay them like employees. They get benefits like their employees. They wear branded shirts like their employees. Even if they’re not, they’re agents, and there is good law out there for also that theory of liability as well.

Steven Babin (21:13):
So, there’s really either a direct theory liability or an agency theory liability that gets you to the corporation, and that’s who’s going to make change, and if you actually care what your clients care about too. We’re not going in litigating because Steven Babin and Kristina Aiad-Toss wanted to change the human trafficking industry. Our clients want that too. They want much moreso than money. They want something to change so this doesn’t happen to the next person. They want to be part of developing and creating that change.

Steven Babin (21:40):
When we’re creating litigation strategy around that, for me at our firm, we think it’s really the corporations are slowing down.

Dan Comunale (21:49):
Gotcha. Kristina or Steve, just so we can move into a little bit of the status updates for the different venues and state MBLs, and so forth, and class actions, will you guys give a little update on where we are there for our audience?

Kristina Aiad-Toss (22:09):
Sure. Just generally overall, we’re seeing here in Ohio, I guess… We can really start here in Ohio because that really set the stage for a lot of these cases and decisions that are coming out, because a lot of the decisions across the country are citing the standard that was established in MA, which was the first case that Babin Law and a coalition of other law firms brought in human trafficking hotel context.

Kristina Aiad-Toss (22:39):
It really all starts there. What we’ve really seen across the country is just a big influx of cases. We’ve also seen the law develop a little bit further. We’ve seen pleading standards tighten a little bit more as opposed to first more general allegations of control, and agency, and also specific facts and red flags to the hotels. Now we’re seeing folks wanting a bit more particularity of allegations, like how much can these cases connect the brand to the plaintiffs, how many specific instances can the plaintiff recall at the hotel, what red flags were present, and then what specific allegations of control did the brand exercise over its franchisees.

Kristina Aiad-Toss (23:28):
I think the pleading standard overall has kind of grown since the first case was filed in 2019. We’ve seen grow in litigation. There was a recent decision, Red Roof Inns out of the 11th Circuit Court of Appeal that did dismiss a claim, but that was largely based on a complaint and the way the complaint was worded. We’ve seen a bit of mixed decisions after that, but overall we don’t really believe this necessarily threatens the course of the lawsuits because it was based on a very specific complaint that pled sex trafficking venture versus just in commercial business ventures, so basically at the end of the day a commercial business venture satisfies what is required to be proved under the TVPRA.

Kristina Aiad-Toss (24:22):
We’ve also seen an MDL in Texas, specifically in the Southern District of Texas, which was recently consolidated in February 2022. That case is specifically against Backpage, but also major hotel brands and franchisee properties. It was initially against Salesforce too, the parent company of Backpage, but that has since been dismissed. This MDL is in its very early stages because it was recently consolidated, so there’s little information about that out there.

Kristina Aiad-Toss (25:02):
Another big decision was the class action case against Porn Hub, which was also recently consolidated earlier this year. That case is based in Alabama. That case involved child pornography that was posted on Porn Hub and also on MindGeek, which is the parent of Porn Hub, so that’s basically a class action that has been brought by two victims of child sex trafficking, and that survived a Motion to Dismiss in February 2022. The court specifically ruled that Section 230 was not applicable, which is typically what the defense that we see, different tech companies, bringing as qualified immunity against these types of lawsuits, but the court ruled it wasn’t applicable because child pornography is illegal contraband. So, that was a pretty revolutionary step in these cases, especially as it pertains to the tech company cases.

Steven Babin (26:04):
Real quick on the update too, what I hear a lot is “Will there be an MDL?” Because we moved for a MDL a couple of years back and the court didn’t give it to us. The reason was, is we had asked for an industry-wide MDL and there had been no industry-wide claims of anything even like conspiracy. I can tell you at this stage here today, I don’t think that we’re going to move for MDL. But, there are a number of consolidated or coordinated case efforts that are going to be occurring, and we’re managing some of those across the country.

Steven Babin (26:37):
For example, in Ohio we have a handful of related cases in front a judge, and we just got an opportunity to have a Special Master to handle all the pretrial issues, discovery issues. So, there will be a pretty coordinated effort there. We filed not just Ohio cases into Ohio too. There are some workarounds that we can get you to file a lot of them. There will be some many mass tort type litigations I think, but I don’t see an MDL in the next coming months coming around.

Susan Barfield (27:15):
That’s interesting. I know, Steve, I’m sure attorneys reach out to you potentially interested in getting involved with these cases. Anything that you share about the difficulty of onboarding these clients when they’re just going back through, having to relive and talk about their story, the trauma that they have to re-experience? If you’re going to receive referrals, what is your specific criteria that you look for in these referrals?

Steven Babin (27:46):
I’ll chop this up a little bit and I’ll do the… If you’re working on what to expect, and Kristina can talk a little bit more about the case guards here that we’re looking at now, but I can tell you if you’re going to do these cases I would say don’t just stick your toe in the water. You got to really do these cases for real. This is different than any mass tort where you can get some medical records, file a short form complaint, and some kind of plaintiff fact sheet, and you can of… The blind leading the blind their way through it, and make some money at the end.

Steven Babin (28:20):
These cases are really involved, and you owe it to these clients to really do a good job. I tell people at our firm all the time that our clients, most of them, have never had anybody do a good job for them ever, whether it’s school, whether it’s parenting, whether it’s interactions with law enforcement, certainly interactions with the hotel industry, and that gives us our one opportunity to at least do a good job for them. Win or lose, at least we can do a good job. What that means is, exactly what you said Susan, training your people in re-traumatization.

Steven Babin (28:49):
Now, we’re lucky, and I think a lot of firms out there are too, because sex abuse/assault is such a hot topic right now that we have some of that skill and expertise in the firm that will worsen the whole sexual assault area. We train our people in re-traumatization. We have a doctor, I don’t know if she’s a medical doctor, but a doctor who’s a CEO of a nonprofit to come in and talk to our people regularly. We have further resources for them too, if our employees are experiencing secondary trauma.

Susan Barfield (29:23):

Steven Babin (29:26):
The workup is involved too because the process, just like any sex assault case, the story comes out and it’s not necessarily linear [inaudible 00:29:36]. As our clients get used to telling their story, and as they build trust with us, and as they get more distance from what happened, that story becomes more linear, and as it stretches out it becomes more linear, more facts are filled into those gaps that weren’t there before.

Susan Barfield (29:48):

Steven Babin (29:50):
That means there’s not just one phone call. There are multiple phone calls, and they’re phone calls that allow us to build a relationship and trust with the client. On top of that, we request a lot of documents. We’re making multiple FOIA requests at state levels, local levels, federal levels. We’re getting medical records, we’re doing complaints and reviews across the whole Internet that we can find, we’re pulling any sex ads that we can find for our client. Quite a few documents going through it.

Steven Babin (30:22):
Then we’re taking cases that have some time on the statute and we’re evaluating them, seeing which ones we want to file first, and going from there. When we’re evaluating them… And again Kristina can tell you what we’re looking at that makes the case that we’ll bring and work up, and then Kristina maybe you can tell them a little bit about what we see makes a really strong maybe A+ grade for purposes of settlement.

Kristina Aiad-Toss (30:50):
Sure, I think just at a very basic level, I think the bare bones criteria, at least at the onset when we’re seeking out these cases and whittling down the criteria, I think it’s just basically if someone was trafficked and they were trafficked at a major brand hotel, or at a hotel, and obviously considering the Statute of Limitations under the TVPRA, which is in the last 10 years, one of the things that we also look for at least the onset too, is these cases can be very re-traumatizing and cover a lot of sensitive materials, and also it requires a lot of our clients too to be able to go through these stories and talk with us, and engage in the process of going through litigation can be pretty, down the line at least, pretty challenging for them.

Kristina Aiad-Toss (31:48):
We do like to be up front with them, build trust with them about that, and also make sure that they are currently in a safe situation and a stable situation to be able to work with our firm and go over these traumatizing topics.

Steven Babin (32:04):
Real quick, I just want to break it down for everyone for four criteria. One, were they trafficked? Two, was it at a major brand qualifying hotel that we have on our list? Three, was it within the last eight years? We’re trying to take cases that have at least two years left on the statute. And four, are they in a safe place/are they currently engaging in commercial sex activity? So, yes, they need to be in a safe place and they can’t be engaging in commercial sex activities currently. They’ve got to stop doing that if that’s something they’re doing. Those are the four criteria. So, traffic, major hotel within the last eight years, safe and not engaging in commercial sex. You can sort of read what kind of facts we found in the best cases as far as being involved.

Susan Barfield (32:51):
Sure. Yeah, that’s helpful. Steve, how would you describe a successful resolution for the human trafficking cases?

Steven Babin (33:02):
Bankrupting one of the big hotel corporations, and a multi-billion dollar settlement is what I’m thinking. If we ever have bankrupt, I’ll get a tear drop tattoo for it.

Susan Barfield (33:11):
Yeah, for sure.

Steven Babin (33:17):
These are seven figure cases all day.

Susan Barfield (33:18):

Steven Babin (33:18):
There are insurance policies for each individual hotel property, so we’re talking about dealing with individual policies for local properties. We don’t have a lot of overlap with 15 people at one property. We’ll probably run into that down the road, but we’re talking in the billions of dollars here, if I’m going to be able to go to sleep at night [inaudible 00:33:38] how many cases we have at our firm at least.

Dan Comunale (33:40):
Yeah, all right. Well, in the essence of time, thank you all very much. I just wanted to… I know we could talk about this-

Steven Babin (33:47):
I feel bad because I cut the scene off, and this is [inaudible 00:33:51].

Dan Comunale (33:52):
It’s totally fine. Again, we didn’t get to cover some of the areas, but we very much thank you. We’d just like to end a little bit on just little things about yourself. Steven, I know Babin Law has grown tremendously in the last couple of years. You’ve clearly taken the policy of hiring people that are significantly smarter than you, having talking to them. Where do you see the growth of Babin Law going in the three to five year span?

Steven Babin (34:21):
Yeah, we’re going to quadruple in size, probably, is the trajectory we’re on. We’ve got really good, really smart, really diverse people at the law firm that hit sort of every category of how you could be diverse. That’s been really important at the firm, as far as that’s the kind of place that I’d want to go to work at. I like that we have people of different backgrounds, and different experiences, and different things that they can bring to the table from their life experiences. I love that they’re smarter than I am, the lawyers here, and we’re wondering just know more facts than I do because I have a lot of facts in my brain.

Steven Babin (34:59):
We’ll get bigger. We’ll keep working in sex abuse and sex trafficking. We’re really building that part of our firm out right now. We’re starting a kind of sex trafficking/sex abuse movement to piggyback off of the MeToo movement where me and another lawyer are going to be on Good Morning America [inaudible 00:35:15] talking about that too. That’s where I see us building our expertise, is in that area right now. Traditional mass torts as well, but this is just an area that we’ve kind of put in the time and spent the hard working hours to get some expertise in it. We’ll probably keep doing down that path right now.

Susan Barfield (35:33):
Yeah. Yeah. Kristina, what about for you? Coming in, like Steve said, this is so different than mass tort, which is coming from a nursing background myself I just see this to be such rewarding work that you’re doing, and life-changing for people. If you were to look at over the next five years, is there a professional accomplishment you would be proud or that you’re striving to achieve?

Kristina Aiad-Toss (35:59):
I’d say in addition to getting a tear drop tattoo as well for every hotel [inaudible 00:36:03]. I’d say in addition to that, I think at the end of the day human trafficking is something that I’ve worked on for a while before I worked at Babin Law. I come from the nonprofit space, so I’ve worked with victims, I’ve done a lot of advocacy work around this issue, and I really think the problem persists because a lot of actors along the way choose to do nothing and look the other way.

Kristina Aiad-Toss (36:31):
So, what I really want to see come out of this is accountability for those that continue to profit, and continue to allow this problem to persist because it really is one of the biggest issues I think facing our country and also the world, because it’s literally happening in every neighborhood. It’s happening in every country across all income levels and populations, women, men, children. You name it. It’s affecting people. So, I think pushing for accountability of the hotel industry and other corporations that often don’t get held accountable for these things is really what I’d like to see happen with these lawsuits especially because there’s not a lot of accountability and ways to hold corporations accountable.

Kristina Aiad-Toss (37:15):
I’d like to play a role in that and see some justice for these victims, and also a bigger institutional-wide change as for how I’m looking at those issues because it really affects everyone at the end of the day.

Susan Barfield (37:30):
Yeah, absolutely. I’m sure people, it’s easy to turn a blind eye until it hits close to him, until this happens to someone that, maybe a family member or someone that you know. Then the reality hits you in the face, that yeah this is happening everywhere. We just really appreciate you guys, like I said, initially coming on today just to talk to us about this. I’ve learned a lot and I know that other folks in the industry will too.

Susan Barfield (37:52):
Say Kristina or Steve, if someone was to reach out and just talk about potentially getting involved, or maybe they have some cases and they don’t really want to work them up… Steve, what you outlined is like the right way to really get involved. This is heavy lifting work. This is not your traditional fill out the short form complaint for all these cases. So, if someone has decided that they have cases that meet your criteria and they don’t work them up, what’s the best way to get in contact with you?

Steven Babin (38:21):
Send them to us, for sure. Even if you don’t want to send us longterm, send them to us, work with us, learn how to do it, and then [inaudible 00:38:27] because we’d rather you learn how to do it the right way. I don’t know, call my cellphone if you’re a lawyer. I’m pretty sure you can give them my cell, 614-746-7740.

Susan Barfield (38:41):

Steven Babin (38:43):
That’s the best way to send me cases if you’re a lawyer or you want to talk about what you might have case-wise. And text me. That’s really the best way to get ahold of me.

Susan Barfield (38:54):
Yeah. Yeah, absolutely.

Dan Comunale (38:56):
For our audience, we’ll provide also the emails to both Kristina and Steve. Again, as Susan said, we are very appreciative of you joining us. For our audience, thank you for tuning in and being with us on this journey as we help attorneys help people. From everyone at Case Works, and our Founder and Chair Susan Barfield, thank you so much for everyone.

Susan Barfield (39:18):

Dan Comunale (39:18):
Have a great day.

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