This column reports on several significant representative decisions from the U.S. District Court for the Eastern District of New York. Judge Ann M. Donnelly denied a motion to dismiss a complaint alleging claims of forced labor and trafficking and, in a second, unrelated matter, denied a mother's petition under the Hague Convention to repatriate her child to England. Chief Judge Margo K. Brodie denied defendants' motion to dismiss the indictment against them or for an in camera review of the grand jury minutes.

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Forced Labor and Trafficking Claims

In Schneider v. OSG d/b/a Odyssey Study Group, 22 CV 7686 (EDNY, Mar. 27, 2024), Donnelly denied defendants' motion to dismiss the complaint of a former member of an alleged cult who asserted violations of the Trafficking Victims Protection Act (TVPA).

For more than 23 years, plaintiff Schneider was a student member of defendant Odyssey Study Group (OSG). Schneider alleged that OSG was "a cult," and that the organization and its leaders coerced him into "perform[ing] thousands of hours of unpaid labor and services by instilling in him a fear that if he did not perform such labor and services, he would endure serious harm." Slip op. 1.