What is Human Trafficking?

Human Trafficking 
United States Commission on Civil Rights 
November 2011 

John Cotton Richmond

Special Litigation Counsel

Human Trafficking Prosecution Unit

United States Department of Justice

john.richmond@usdoj.gov

(202) 305-4044

Today’s Goals 
 

• Deconstruct 6 Myths about Human Trafficking

• Understand Federal Human Trafficking Statutes 
  

• Review the Investigation & Prosecution Model 
  

• Define Human Trafficking Indicators 
  

What is Human Trafficking? 
 

Working Definition 

  “Human Trafficking” is compelling someone to work or to engage in a commercial sex act. 
 


 




The Big Picture  
 


Protect specific victims through rescue, services, and a victim centered approach to the rule of law. 


Prevent human trafficking offenses by dismantling trafficking networks, building awareness, and creating deterrence. 


Prosecute the perpetrators for their criminal conduct to the full extent of the law.




What Does “Victim-Centered” Mean?

• Non-Prosecution of Victims
• Vindicates victim’s individual rights
• Empowers victim as an active participant
• Aids transition from traumatized victim to empowered survivor

Transform Law Enforcement Culture

• Abandonment of pre-conceptions
• Evolution of trauma-informed approaches
 


Victim-Centered Approach




Myths About Human Trafficking




Human Trafficking Myths 


1.  Slavery is a historical blight that no longer exists. 


• 12.3 Million victims of human trafficking

U.S. Department of State, Trafficking in Persons Report 2010 


• 27 million people held in slavery worldwide

Free The Slaves 2011 


• 100,000 children in U.S. are in sex trade

Polaris Project 2011




Human Trafficking Myths 


The law does not require foreign victims or defendants.

United States v. Evans, 476 F.3d 1176 (11th Cir. 2007) (both the Defendant and the human trafficking victim were United States citizens).  
 


2. There are no foreigners in the case




Human Trafficking Myths 


3. Trafficking Involves Movement and Borders 


• No Borders Needed
• No Legal Requirement 
  
• Trafficking is Misleading 
  
•   Coercion not Movement 
  
• Traffickers Don’t See          Borders 
  
 


 




COERCION 


Trafficking 


Human Trafficking Myths 


3. Trafficking Involves Movement and Borders 


Undocumented

Voluntary

Crime against boarders

Transportation




COERCION 


MOVEMENT 


Trafficking 


Smuggling 


Human Trafficking Myths 


3. Trafficking Involves Movement and Borders




COERCION 


MOVEMENT 


Trafficking 


Smuggling 


Human Trafficking Myths 


3. Trafficking Involves Movement and Borders 


Undocumented

Voluntary

Crime against boarders

Transportation 


Citizen or Undocumented

Coerced / Involuntary

Crime against Person

Exploitation




Human Trafficking Myths 


You Cannot Take a Picture of Coercion 


3. Trafficking Involves Movement and Borders




Human Trafficking Myths 


4.  This case does not involve prostitution or sex. 


•   “Recent studies show the majority of human trafficking in the world takes the form of forced labor.”  Dept. of State’s 2010 Trafficking in Persons Report.
 


      Restaurant Workers   Domestic Servants

      Farmers    Hotel Employees

      Factory Workers   Restaurant Workers

  

•    The Law Has No Occupation Limitation

Don’t Forget About the Labor Cases




Human Trafficking Myths 


5. The “victims” have to think they are “victims.” 


Often human trafficking victims do not self identify as victims.

•    Shame
•    Lack understanding about their rights
•    Distrust of law enforcement
•    Still believing the coercive lies of the perpetrator
•    Not ready to admit the truth to themselves yet

Human Trafficking Myths 


6.    There Will Not be Prior Inconsistent Statements

•    Embrace prior inconsistent statements. 
•    Most trafficking victims will not tell the complete truth during the first few interviews.
•    Evolving statements can be evidence of the coercive scheme

What Human Trafficking Is Not! 


•   Illegal Child Adoption
•   Trade in Human Organs
•   Child Pornography
•   Prostitution (Not a Federal Vice Squad)
•   Labor Violations
•   Poor Working or Living Conditions
 


There are other statutes that deal with theses offenses.




Federal Laws 


Involuntary Servitude and Slavery Crimes

• 18 U.S.C. § 1581 (Peonage)
• 18 U.S.C. § 1583 (Enticement Into Slavery)
• 18 U.S.C. § 1584 (Involuntary Servitude)

_____________________________________ 


Trafficking Victims Protection Act

• 18 U.S.C. § 1589 (Forced Labor)
• 18 U.S.C. § 1590 (Trafficking Into Servitude)
• 18 U.S.C. § 1591 (Sex Trafficking)
• 18 U.S.C. § 1592 (Document Servitude)

Forced Labor | 18 U.S.C § 1589  


Knowingly 


Provides or Obtains Labor or Services of a Person 


Through  1 of 4 Prohibited Means 


Force or Threats 


Serious Harm 


Abuse of Law 


Scheme Plan or Pattern 


1 


2 


3




Forced Labor | 18 U.S.C § 1589  


Knowingly 


Provides or Obtains Labor or Services of a Person 


Through  1 of 4 Prohibited Means 


Force or Threats 


Serious Harm 


Abuse of Law 


Scheme Plan or Pattern 


1 


2 


3




Forced Labor | 18 U.S.C § 1589  


Knowingly 


Provides or Obtains Labor or Services of a Person 


Through  1 of 4 Prohibited Means 


Force or Threats 


Serious Harm 


Abuse of Law 


Scheme Plan or Pattern 


1 


2 


3




Forced Labor | § 1589  


Element 3: Four Prohibited Means

1. Force, or Threats of Force or Physical Restraint

2. Serious Harm or Threats of Serious Harm

3. Abuse or threatened abuse of law or legal process

4. Scheme, plan, or pattern intended to instill fear

          of serious harm or physical restraint to any                person 


Only Need 1 Prohibited Means.




Forced Labor | § 1589  


Prohibited Means: Serious Harm: 


Physical Harm  Nonphysical Harm

* Threats   * Psychological Harm

* Beatings   * Financial Harm

* Sexual Violence  * Reputational harm 


“that is sufficiently serious, under all the surrounding circumstances, to compel a reasonable person of the same background and in the same circumstances to perform or to continue performing labor or services in order to avoid incurring that harm.”

                                                             18 U.S.C. § 1589(c)(2)

 




Forced Labor | § 1589  


Prohibited Means: Abuse of Legal Process 


•    Threat of deportation, arrest, detention, institutionalization
•    “Warnings” unlawful where used to coerce.
 


United States v. Farrell, 563 F.3d 364, 373 (8th Cir. 2009).

United States v. Calimlim, 538 F.3d 706, 716 (7th Cir. 2008).

United States v. Veerapol, 312 F.3d 1128, 1131-32 (9th Cir. 2002).

United States v. Paris, 2007 WL 3124724 (D. Conn. 2007) (unpublished). 





Forced Labor | § 1589  


Prohibited Means: Abuse of Legal Process 


The term “abuse or threatened abuse of law or legal process” means the use or threatened use of law or legal process, whether administrative, civil, criminal, in any manner or for any purpose for which the law was not designed, in order to exert pressure on another person to cause that person to take some action or refrain from taking some action. 


18 U.S.C. § 1589(c)(1)

 




Forced Labor | § 1589  


Prohibited Means: Scheme, Plan, Pattern

Totality of Circumstances from the Victim’s Perspective

•    Manipulation of debts
•    Verbal abuse and intimidation
•    Demeaning and demoralizing conduct
•    Psychological manipulation and control
•    Confiscation of identification documents
•    Inhumane living and working conditions
•    Ominous comments
•    Monitoring and surveillance
•    Sexual Abuse

 




Forced Labor | § 1589  


Penalties

• Imprisonment up to Life
• If death results; OR
• If acts include kidnapping (or attempt), aggravated sexual abuse (or attempt), or an attempt to kill
• Imprisonment up to 20 years 
  
• No aggravating factors

 




Sex Trafficking | § 1591 


Two Crimes in One




Sex Trafficking | § 1591 


1) Knowingly recruited, enticed, harbored, transported, provided, obtained, or maintained a person; or knowingly benefitted, financially or by receiving something of value from participating in a venture that did so; 


2) Knew, or in reckless disregard of the fact that, force, fraud, or coercion would be used to cause the person to engage in commercial sex acts; 


3) Acts were in or affecting interstate commerce 


Crime 1: By Force, Fraud, or Coercion




Knowingly 


Recruited, enticed, harbored, transported, provided, obtained or maintained or Benefit Financially 


Interstate or Foreign Commerce 


Knowing or in Reckless Disregard  


Commercial Sex Act 


1 


2 


3 


Force, Fraud, or Coercion   


4 


5 


6 


Sex Trafficking | § 1591 


Crime 1: By Force, Fraud, or Coercion




Knowingly 


Recruited, enticed, harbored, transported, provided, obtained or maintained or Benefit Financially 


Interstate or Foreign Commerce 


Knowing or in Reckless Disregard  


Commercial Sex Act 


1 


2 


3 


Force, Fraud, or Coercion   


4 


5 


6 


Sex Trafficking | § 1591 


Crime 1: By Force, Fraud, or Coercion 


Two Intent Requirements




Sex Trafficking | § 1591  


2 Knowledge Requirements

• “Knowingly” recruits, entices, harbors, transports, provides, obtains, or maintains a person for a commercial sex act or benefits financially.
• “Knowing, or reckless disregard” of the fact that force, fraud or coercion would be used or that victim was under 18 
  
• Knowledge of age is required to prove crime but not for victim status
• Reasonable Opportunity to Observe

 




Knowingly 


Recruited, enticed, harbored, transported, provided, obtained or maintained or Benefit Financially 


Interstate or Foreign Commerce 


Knowing or in Reckless Disregard  


Commercial Sex Act 


1 


2 


3 


Force, Fraud, or Coercion   


4 


5 


6 


Sex Trafficking | § 1591 


Crime 1: By Force, Fraud, or Coercion 


Two Processes




Sex Trafficking | § 1591 
 


      


Crime 1: By Force, Fraud, or Coercion




Sex Trafficking | § 1591 


What is Coercion?

18 U.S.C. § 1591(e)(2) defines “coercion” as

•    threats of serious harm to or physical restrain against any person
•    any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint
•    abuse or threatened abuse of the legal process
 


**Basically the same as the prohibited means in § 1589** 


Crime 1: By Force, Fraud, or Coercion




Sex Trafficking | § 1591 


1)  Knowingly recruited, enticed, harbored, transported, provided, obtained, or maintained a person; or knowingly benefitted, financially or by receiving something of value, from participating in a venture that did so; 


2)  Knew, or in reckless disregard of the fact that the person was under 18 (or the Subject had a reasonable opportunity to observe the minor) and will be caused to engage in a commercial sex act. 18 U.S.C. § 1591(c). 


3)  Acts were in or affecting interstate commerce 
 


Crime 2: By Age




Knowingly 


Recruited, enticed, harbored, transported, provided, obtained or maintained or Benefit Financially 


Interstate or Foreign Commerce 


Knowing or in Reckless Disregard  


Commercial Sex Act 


1 


2 


3 


Under 18 


4 


5 


6 


Sex Trafficking | § 1591 


Crime 2: By Age




Knowingly 


Recruited, enticed, harbored, transported, provided, obtained or maintained or Benefit Financially 


Interstate or Foreign Commerce 


Knowing or in Reckless Disregard  


Commercial Sex Act 


1 


2 


3 


Under 18 


4 


5 


6 


Sex Trafficking | § 1591 


Crime 2: By Age 


• Same Two Intent Requirements
• Same Two Processes 
  
• Don’t Need Force, Fraud, or Coercion, but . . . . 
  

Sex Trafficking | § 1591 


Sex Trafficking of a Minor 


• Under 18 (“not attained the age of 18”)
• Knowing or in Reckless Disregard 
  
• Reasonable Opportunity to Observe 
  

     18 U.S.C. § 1591(c) 
 
 


Crime 2: By Age




Knowingly 


Recruited, enticed, harbored, transported, provided, obtained or maintained or Benefit Financially 


Interstate or Foreign Commerce 


Knowing or in Reckless Disregard  


Commercial Sex Act 


1 


2 


3 


Under 18 


4 


5 


6 


Sex Trafficking | § 1591 


Force, Fraud, or Coercion   


Or




Sex Trafficking | § 1591 


What is a “Commercial Sex Act”?

• “any sex act, on account of which anything of value is given to or received by any person.” § 1591(e)(3).
• No requirement that the Defendant had sex with the victim.

United States v. Williams, 2011 WL 1958148 (3d Cir. 2011) (unpublished).

• Compare 18 U.S.C. § 2246 (2) “sexual act” and 18 U.S.C. § 2246 (3) “sexual contact”
• For “exotic” dancing or massage consider § 1589 Forced Labor

In or Affecting Interstate or Foreign Commerce

• Crossing state lines
• Interstate communications, facilities, or supplies,
• Aggregate affect on intrastate commercial or economic activity
 


No One Has to Travel Across State Lines! 


Sex Trafficking | § 1591




In or Affecting Interstate or Foreign Commerce

• United States v. Chappell, 2010 WL 1131474 (D.Minn. 2010) (noting that various internet sites were used to promote the minor’s prostitution services).
• United States v. Anderson, 560 F.3d 275, 280 (5th Cir. 2009)(hotel bills, cell phone bills, and clothing purchases sufficient for the interstate commerce element).
• United States v. Flint, 2010 WL 3521922 (6th Cir. 2010) (unpublished) (finding that purchasing drugs, clothing, hair extensions, fake nails, and renting a was sufficient to satisfy the interstate commerce element.).
 
 


Sex Trafficking | § 1591




Sex Trafficking | § 1591 


Imprisonment of 15 years to Life

• Force, fraud, or coercion used; OR
• Defendant enticed, harbored, transported, provided, or obtained minor under 14 years old.
• Mandatory Minimum of 15 Years.
• United States v. Wallace, 605 F.3d 477, 479 (8th Cir. 2010) (the court applied the fifteen year mandatory minimum sentence and upheld the trial court’s upward departure to twenty years imprisonment was affirmed).
 


Imprisonment of 10 Years to Life

• Defendant enticed, harbored, transported, provided, or obtained a minor who was at least 14 years old but under 18 years old.
• Mandatory Minimum of 10 Years.

 




Sex Trafficking | § 1591 
 


Mandatory Life Imprisonment for Repeated Sex Offenses against Children § 3559(e) 


     Mandatory life imprisonment if the defendant in a 1591 sex trafficking of a minor prosecution has a prior state or federal conviction for a sexual offense against a minor who has not attained the age of 17. 





Detention Issues 


Detention

• 18 U.S.C. § 3142(e) expands the Government’s authority to detain defendants charged with trafficking offenses. 
• Offenses with a maximum term of imprisonment of 20 years or more raise a rebuttable presumption of pre-trial detention. 
 


Peonage (§ 1581)      Forced Labor (§ 1589)

Enticement into Slavery (§ 1583)   Trafficking into Slavery (§ 1590)

Involuntary Servitude (§ 1584)     Sex Trafficking (§ 1591)

 




Other Statutes to Consider 


• Mann Act, 18 U.S.C. §§ 2421-23
• Immigration Laws, 8 U.S.C. §§ 1324, 1328
• Labor Laws, 29 U.S.C. §§ 1801, 1851
• Money Laundering, 18 U.S.C. § 1956
• Extortion, 18 U.S.C. § 894
• Kidnapping, 18 U.S.C. § 1201
• Hostage-Taking, 18 U.S.C. § 1203
• Document Fraud, 18 U.S.C. § 1546
• False Documents, 18 U.S.C. § 1028

Investigation & Prosecution Model 


How to Prove the Case




Investigation & Prosecution Model 


•  Why is the model different that most other crimes?
• Multiple Law Enforcement agencies
• AUSAs and Main Justice Prosecutors
• Social Service providing NGOs
• Legal Service providing NGOs or Pro Bono Victim Lawyers
• Federally funded task forces
• Multiple victims
• Victim / Witness coordinators

All parties play an important part . . . but there are a lot of cooks in the kitchen 


• Victim Centered Approach

Investigation & Prosecution Model 


Four Aspects of the Investigation 


1. The Objective Facts

2. The Victim’s Story

3. Corroborating the Victim

4. Anticipating Defenses 





Investigation & Prosecution Model 


The Objective Facts: Initial Areas of Focus

• Determine the Business Model
• Type of Labor or Services
• Age of Victims
• Receipts, invoices
• Ledgers and journals
• Computers and cell phones
• Vehicles
• Houses, Apartments, and Store Fronts

 




Victims




Victims 


•    Victim Testimony is Essential
•    Only Victims Can Answer: “Why?”
• Crime requires showing of “labor obtained    by coercion” - subjective component
• Only the Victim can explain the Climate of Fear
•    We Lose Cases without Victims

Victims 


Maslow's Hierarchy of Needs




Victims 


Stabilize the Victim

•   Access pre-certification services
•   Expedite eligibility letter for minors or certification for adults
•   Victim provisions broader than criminal statutes; qualification is independent of whether the case can be prosecuted
• Victim may be qualified based on credible extrinsic evidence

Victims 


Continued Presence

•   Temporary immigration status
•   Initiated by Law Enforcement for the Benefit of Law Enforcement
•   Any person compelled to provide labor or engage in a commercial sex act qualifies
•   Based on credible evidence, extrinsic or intrinsic
•   Prosecutability  of the case is irrelevant
•   Corroboration  of the victim is not required
•   Victim does not have to self identify as a victim
•   Last for 1 year (can be renewed)
•   Comes with an Employment Authorization Card
• 22 U.S.C. § 7105(b) and 28 C.F.R. § 1100.35

Victims 


T – Non-Immigrant Visa

•   Temporary immigration status
•   Initiated by Victims for the Benefit of  Victims
•   With or without cooperating with law enforcement (I-914B)
•   Comes with an Employment Authorization Card
•    Lasts for 5 years
•    Provides for close family members to enter the USA on “derivative T visas.”
•    Statements in support of the T visa are discoverable
•   Victims can apply for their T visas while on Continued Presence
•   8 U.S.C. § 1101 (a)(15)(T); 8 C.F.R. § 214.11

The Victim’s Story 


• Earn Trust
• Empower victim with choices – even small ones
• Victim trauma, shame, fear, loyalty, and distrust
• Combination of violent crime, sex crime, organized crime, financial crime, alien smuggling, and labor exploitation
• Avoid Direct Questions
• “What is your highest level of education completed?”
• “When did you illegally enter the United States?”
• “How long have you been a prostitute?”
• Do not use cop-lingo
• Assume prostitution, illegal status
• Be prepared for bad judgment.
• Expect evolving statements

Coercion:  Climate of Fear 


• Isolation and Poor Working Conditions
• United States v. Farrell, 563 F.3d 364, 373 (8^th Cir. 2009)
• General atmosphere of violence  
  
• United States v. Harris, 701 F.2d 1095, 1100 (4th Cir. 1983)
• Conduct toward other victims 
  
• United States v. Bibbs, 564 F.2d 1165, 1168 (5th Cir. 1977)
• Violence among co-defendants 
  
• United States v. Alzanki, 54 F.3d 994, 999 (1st Cir. 1995)
• Sexual abuse by a co-conspirator 
  
• United States v. Udeozor, 515 F.3d 260 (4th Cir. 2008)

Coercion:  Climate of Fear 


Totality of Conduct and Conditions

• Forced to work as a domestic servant for approximately 15 hours per day / 7 days each week without compensation.
• Struck [victim] with hands, closed fists, and other objects in order to compel her to work. 
  
• Continually warned and threatened [victim] that she would be jailed or deported if she informed law enforcement, other authorities, or other people about her working and living conditions. 
  
• Isolated [victim] by forbidding her to talk on the phone, make new acquaintances, or leave the defendants’ houses by herself, and by requiring her to remain in the garage when guests would visit. 
  

Coercion:  Dual Use of Debt 


Victim owes Owner

• Smuggling Debts
• Room and Board Debts
• Tools of Trade  Debts

Owner owes Victim

• Back Wages
• Tanda / Pyramid  Schemes
• Deposits
 


Distinguish Third Party Debt Not Related to Labor 





Coercion: Trafficking Indicators 


Isolation

Monitoring and surveillance

Restricted or monitored communication

‘Spokesperson’ for group

Locks and fences

  

Debts and Wages

Loans

Deposits

Owed Back Pay

Low or No Pay 


  


Working and Living Conditions

Poor living or working conditions

Transportation patterns

Location of personal items

Not promised work or location

Harsh penalties and work rules 


 Statements

Inconsistent or rehearsed stories

Distrust of Law Enforcement 


Control of Documents

Control over identification documents  
 


Indicators Alone Do Not Equal Trafficking

Must Tie to Coercion




Corroborate the Victim 


Witnesses

• Background, vulnerability, recruitment
• Isolation witnesses & ‘negative’ witnesses
• Never saw victim out alone
• Never heard victim speak English
• Previous victims
• Outcry witnesses
• Witnesses to any interactions
• Visitors
• Customers

Corroborate the Victim 


Physical Evidence

• Wire transfers, ledgers, bank records, receipts, computers
• Physical surroundings causing isolation and fear
• Visas, immigration and travel records
• Phone records
• Letters to victim’s family
• Photos, videotapes
• Medical records
• Leases, registrations linking subjects
• Prostitution paraphernalia: condoms, lubricant, lingerie, medications, tickets, business cards

Corroborate the Victim 


Financial Investigation

• Corroborate exploitation by proving economic disparity
• Identify additional defendants
• Charge and prove related financial crimes
• Calculate mandatory restitution under § 1593
• Identify assets for mandatory forfeiture under § 1594(b)

Corroborate the Victim 


International Investigation

• Circumstances of recruitment
• Victim’s background and vulnerabilities
• Visa applications
• Money remittances
• Outcry witnesses
• Isolation witnesses
• Prior or subsequent victims
• Threats to victim’s family
• Birth certificates and identity documents
• Complaints to authorities
• Overseas co-conspirators’ acts and statements
• Extradition of fugitive defendants

Think of Indicators Like Balloons.




Poor Work Conditions 


Employment Discrimination 


Wage and Hour Violations 


Location of Identity Documents 


Workplace Assault 


Focus on how these things are tethered to the coercive scheme. 


Debts 


Monitored Movement




Defenses




Best NFL Defense of All Time: 1976 Steelers

•   Allowed only 14 total touchdowns during the regular season
•   Allowed only 138 points during regular season
•   Shut out their opponents 5 times
•   During the last 9 games of the season, they held their opponents to an average of 2.7 points per game.
•   The best defense still lost and did not make the Super Bowl.
 


Defense




Immigration Lottery Winner! 


•   Legal Status to stay in the United States
•   Work authorization
 


“She exaggerated her case, and it suited everyone’s purpose to just go along with it.”

-- Attorney for Def. Evelyn Theodore

    New York Times (May 18, 2008) 


• Front Issues in Voir Dire
• Outweighed by corroboration
• Compare Benefits to Coercion
 


Defenses:  Benefits Bias




Defenses:  Could Have Escaped




Defenses:  Initial Consent 


“If a person willingly begins work, but later desires to withdraw and is then forced to remain… by the use or threatened use of coercion, that person’s service becomes involuntary.”   


Pattern Crim. Jury Instr. 11th Cir. § 59.

 




Defenses:  Payment of Wages 


“Whether a person is paid a salary or wage is not determinative of whether that person has been held in involuntary servitude….[I]f a person is forced to labor against that person’s will by the use or threatened use of coercion, such service is involuntary even though the person is paid…” 

Pattern Crim. Jury Instr. 11th Cir. § 59.




Defenses:  Better Off 


United States v. Djoumessi, 538 F.3d 547, 553 (6th Cir. 2008) (Even if victim had “independent reasons for staying in this country,” jury could conclude that it was coercion, “not [victim’s] innocent hopes and dreams, that reasonably made her feel compelled to serve....[Defendant] cannot escape [the law] by contending that he subjected the servant to slightly less wretched conditions than she would have experienced elsewhere.”). 


United States v. Nnaji, No. 4:09-CR-172-A (NDTX 2010)



•   Victims Evolving Statements
• Avoid knee jerk reaction
• Victim Trauma, Shame, Fear, Loyalty, and Distrust
• Protracted relationship with Trafficker
• These cases take time
• Prepare for Cross Examination on Prior Inconsistent Statement - Make them evidence of the exploitation
•   Victim Turned Enforcer
• United States v. Moss, 2010 WL 1986243 (9th Cir. 2010) (unpublished) (upholding the Section 1591(a)(2) conviction where Brooks joined Moss to make money for something she wanted to do, recruit and managed prostitutes, and handed the organization’s finances when Moss was absent even though Brooks was in other respects a victim.).
 
 


Practical Matters




Human Trafficking 
United States Commission on Civil Rights 
November 2011 


John Cotton Richmond

Special Litigation Counsel

Human Trafficking Prosecution Unit

United States Department of Justice

john.richmond@usdoj.gov

(202) 305-4044