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Schneider v. OSG LLC

TVPA Claims Against 'Cult' Survive; Threat of Serious Harm Sufficiently Alleged

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MEMORANDUM DECISION AND ORDER For more than 23 years, the plaintiff was a member of the Odyssey Study Group (“OSG”), which he alleges was “a cult” in which 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.” (ECF No. 1 1.) He alleges violations of forced labor and trafficking laws. The defendants move to dismiss the complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). For the following reasons, the motion is denied.1 BACKGROUND The following facts are drawn from the complaint and assumed to be true, with all reasonable interferences drawn in the plaintiff’s favor. See Peretti v. Authentic Brands Group LLC, 33 F.4th 131, 137 (2d Cir. 2022). I. The Odyssey Study Group Sharon Gans Horn and her husband, Alex Horn, founded the Odyssey Study Group (“OSG”) in about 1980. (ECF No. 1

12, 13.) Gans Horn was OSG’s head “teacher” until her death in 2021. (Id. 16.) She led the organization with an “inner circle” of trusted “lieutenants,” including defendants Lorraine Imlay, Minerva Taylor, and Gregory Koch. (Id. 17.) OSG “operated in secret” as an “esoteric school” that promoted the teachings of a “philosopher” named George Gurdjieff and one of his students, Peter Ouspensky, “purport[ing] to provide [OSG] ‘students’…tools to enrich the Students’ lives, [and] to improve the Students’ psychological well-being and to achieve overall success.” (Id.

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