*1 Jonathan Baram
Po Box 219
Atlantic Beach, N Y 11509
917 459 2209 1:20-CV-09522 July 8, 2024
Dear the honorable Judge
Valerie Figueredo
Before: Ronald M. Gould, Sandra S. Ikuta, and Danielle J.
Forrest, Circuit Judges.
Opinion by Judge Ikuta
SUMMARY*
Trafficking Victims Protection Reauthorization Act
The panel affirmed the district court's order staying proceedings in an action under the Trafficking Victims Protection Reauthorization Act pending the resolution of a criminal action.
Ten plaintiffs sued Daniel Fitzgerald under the civil remedy provision of the TVPRA, 18 U.S.C. § 1595(a), for multiple sex trafficking violations, among other things. The government intervened and moved to stay the litigation pending the resolution of a criminal action involving a different defendant, Peter Nygard. The district court granted the stay *3 motion under 18 U.S.C. $ 1595(b) (1), which requires that any civil action filed under § 1595(a) "shall be stayed during the pendency of any criminal action arising out of the same occurrence in which the claimant is the victim." I am requesting to stay the default judgment against me.
Thank you for your time and consideration
Jonathan Baram