New York, NY – October 28, 2026 — National insurance defense trial firm Tyson & Mendes, LLP announced today it secured a significant defense victory on behalf of a hotel franchise owner in a federal lawsuit alleging civil liability under the Trafficking Victims Protection Reauthorization Act (TVPRA). The United States District Court for the Southern District of New York granted the defense’s motion to dismiss, dismissing all claims against the firm’s client with prejudice.

The plaintiff alleged sex trafficking occurred at several hotels, one of which was owned by a Tyson & Mendes client and sought to hold the operators of the hotels and their franchisers liable on the theory they knew or should have known of the alleged trafficking and financially benefited from providing hotel accommodations. Recognizing deficiencies in the complaint, Tyson & Mendes Senior Counsel Heather M. Abissi, a member of the firm’s New York office with extensive experience in federal litigation and dispositive motion practice, prepared a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). The defense argued the allegations failed to establish the necessary element of participation in a sex trafficking venture required to impose civil beneficiary liability under the TVPRA. The court agreed, finding the alleged provision of ordinary hotel services, without additional facts establishing participation in a trafficking venture, was insufficient to state a viable claim. The court further concluded the complaint failed to plausibly allege a shared enterprise or common undertaking between the defendant and the alleged trafficker.

“This case turned on an important distinction between allegations of knowledge and the actual requirements for imposing liability under federal law,” said Abissi. “The complaint did not allege facts sufficient to establish our client participated in a trafficking venture. By focusing on that critical deficiency, we were able to secure dismissal of all claims against our client with prejudice. We are mindful of the impact of trafficking on victims and communities alike and appreciate the Court’s intentionality in assessing the claims in this difficult case.”

“This outcome reflects the strength of our attorneys’ strategic approach to complex litigation and their ability to identify opportunities for early, decisive resolution,” said Cathleen Kelly Rebar, Tyson & Mendes’ Northeast Regional Managing Partner. “Heather’s work demonstrates the value of focused legal advocacy that protects our clients from legally deficient claims while avoiding the substantial costs and uncertainties of prolonged litigation, and she successfully leveraged the law along with responsibility, reasonableness, and common sense, which are key components of The Apex.”

The Apex℠ is the firm’s trial-tested and data-backed blueprint for the defense to stop nuclear outcomes, first revealed in Nuclear Verdicts®: The Apex – Break the Pattern, released last year at the same time as the launch of spinoff consulting firm Apex Defense Consulting.

The successful dismissal further reinforces Tyson & Mendes’ expertise in delivering effective, strategic defense representation in complex, high-exposure litigation nationwide.

About Tyson & Mendes LLP

Tyson & Mendes LLP is a nationwide, AV-rated litigation and trial firm specializing in insurance defense and protecting its clients from Nuclear Verdicts®. Founded in 2002 by Robert Tyson and Patrick Mendes, the firm has experienced tremendous growth, with offices across the United States. Tyson & Mendes is known for its expertise in defending corporations, insurance companies, and their clients against Nuclear Verdicts®.

Serving 22 states with 29 offices nationwide, Tyson & Mendes is one of the fastest-growing civil defense firms in the U.S. and is proud to offer one of the fastest and clearest paths to partnership for its attorneys of any mid-sized law firm in the U.S. The firm is honored to be recognized as a 2024 and 2025 Best Law Firm by Best Lawyers, named a 2026 Best Company to Work For: Law Firms edition by U.S. News & World Report, shortlisted for the PropertyCasualty360 2026 Insurance Luminaries Award, and has an extensive trial bench of attorneys recognized by Best Lawyers 2026, Best Lawyers: Ones to Watch 2026, and Super Lawyers.

For more information, visit www.tysonmendes.com.

About Apex Defense Consulting

Apex Defense Consulting is a specialized insurance defense consulting firm, offering educational, community, and consulting services via a slate of experienced trial lawyers and Nuclear Verdict® experts. Founded in 2025, Apex Defense Consulting is the first of its kind within the insurance defense industry and is poised to revolutionize the industry with The Apex℠, the first and only data-backed and trial-tested blueprint for the defense to stop outsized and unjust Nuclear Verdicts®.

For more information, visit www.apexdefenseconsulting.com.

For Press Inquiries, Contact:
Debbie Caldwell
Plat4orm Pr
Debbie@plat4form.com

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