*3 (Id. at PageID 3649, citing to M.A. v. Wyndham Hotels & Resorts, Inc., 425 F. Supp. 3d 959, 968 (S.D. Ohio 2019).)

G6 counters that Plaintiff's requests are not relevant to her claim under Section 1595(a). (Resp. at PageID 3819.) G6 claims that “discovery is only relevant under this statute if it tends to prove or disprove these specific elements: 1) knowing benefit, 2) from participation in a venture, 3) that venture violated TVPRA as to the plaintiff, and 4) knowledge (actual or constructive) that the venture violated the TVPRA as to the plaintiff.” (Id. at PageID 3833 (emphasis added).) G6 argues that the “relevant inquiry is venture-specific or property-specific, not general knowledge.” (Id.)

The Court finds that G6's general knowledge of sex trafficking is relevant to Plaintiff's TVPRA claim. G6's general knowledge of sex trafficking could reasonably bear on how G6 should have interpreted signs of A.W.’s alleged trafficking. Moreover, this Court has repeatedly held that allegations of general knowledge and failure to act constitute constructive knowledge, including in this case. A.W. v. Red Roof Inns, Inc., No. 2:21-CV-04934, 2022 WL 17741050, at *6 (S.D. Ohio Dec. 16, 2022) (“This Court has previously held that notice of ‘the prevalence of sex trafficking generally at their hotels,’ the failure ‘to take adequate steps to train staff in order to prevent its occurrence,’ and signs that ‘should have alerted staff to [Plaintiff's] situation’ are sufficient to meet the constructive knowledge requirement.”) (citing M.A., 425 F. Supp. 3d at 968); see also S.C. v. Wyndham Hotels & Resorts, Inc., No. 1:23-CV-00871, 2024 WL 277117, at *1 (N.D. Ohio Jan. 25, 2024) (“General knowledge in combination with facts about S.C.’s particular circumstances can establish that the Red Roof Defendants should have known about S.C.’s trafficking. That is because general knowledge about sex trafficking could color how the Red Roof Defendants should have interpreted signs of S.C.’s trafficking.”).

G6's opposition is unpersuasive and misconstrues both the law and Plaintiff's position. First, G6 inserts the phrase “as to the plaintiff” into the language of Section 1595(a). (Resp. at PageID 3833.) G6 also cites T.P. v. Wyndham Hotels & Resorts, Inc., No. 2:21-CV-04933, 2022 WL 17363234, at *7 (S.D. Ohio Dec. 1, 2022) and S.C. v. Wyndham Hotels & Resorts, Inc., No. 1:23-CV-00871, 2024 WL 2186173, at *6 (N.D. Ohio May 15, 2024) for support, but neither case stands for the proposition that general knowledge is irrelevant. In fact, both cases indicate the opposite. In T.P., the Court noted that “[t]his Court has previously held that notice of ‘the prevalence of sex trafficking generally at their hotels,’ the failure ‘to take adequate steps to train staff in order to prevent its occurrence,’ and signs that ‘should have alerted staff to [Plaintiff's] situation’ are sufficient to meet the constructive knowledge requirement.” 2022 WL 17363234, at *7 (citing M.A., 425 F. Supp. 3d at 968). In S.C., the Northen District of Ohio held that only general knowledge about industry-wide sex trafficking was not sufficient to overcome summary judgment, citing its prior discovery order that held general knowledge to be relevant. 2024 WL 2186173, at *6 (citing S.C., 2024 WL 277117, at *1). In addition, G6 argues that Plaintiff “grossly overstates” this Court's prior holdings. (Resp. at PageID 3835–36.) It appears that G6 makes the inapposite argument that this Court should disregard those holdings because they were rulings on motions to dismiss and not on the proper scope of discovery. (Id.) G6, however, fails to explain how general corporate knowledge of sex trafficking would not be relevant considering this Court's holdings that corporate knowledge bears directly on the constructive knowledge element of a TVPRA claim.

*4 Second, G6 frequently mischaracterizes Plaintiff's requests. G6, for example, claims that Plaintiff seeks to “plumb information concerning any incident at any other G6 hotel—involving other people in other geographies—during other periods of time.” (Resp. at PageID 3819 (emphasis in original).) Plaintiff, however, clearly seeks information regarding a specific type of incident: “any incident of commercial sex/prostitution/human sex trafficking of which G6 corporate and Motel 6 corporate had knowledge of across its Motel 6 properties.” (Reply at PageID 4123.)

Having found that Plaintiff meets her burden under the relevancy inquiry, the Court turns to whether her requests are proportional.[2]

B. Proportionality

Plaintiff argues that her discovery requests are proportional under the Rule 26(b) factors.[3](Mot. at PageID 3652–61.) G6 only contests the last factor—whether the burden outweighs the benefit—so the Court will only consider the parties’ arguments on that factor. (Resp. at PageID 3839–40.)

Plaintiff maintains that the burden of the proposed discovery does not outweigh its likely benefit. (Mot. at PageID 3661.) Plaintiff claims that “much of the information that will be gathered in this case can be utilized in the other G6 cases that are before this Court.” (Id.) G6 counters that Plaintiff's requests place an “onerous burden” on G6, as compliance would result in hundreds of thousands of documents and attorneys’ fees. (Resp. at PageID 3840, 3828–31.) G6 contends that it “would need to collect documents on an immense scale at a disproportionate cost.” (Id. at PageID 3840.) G6 reiterates its claim that the information sought is irrelevant. (Id.) Plaintiff, in her reply, emphasizes that G6 misstates her requests and fails to demonstrate that her requests are not proportionate. (Reply at PageID 4141.) Plaintiff also notes that G6's declarations draw “conclusions of burden based on...unrequested searches.” (Id. at PageID

4135.)

The Court finds that G6 has not established that the burden of the proposed discovery outweighs its likely benefit. G6 primarily bases its burden argument on its contention that Plaintiff's requests are not relevant. (Resp. at PageID 3839–40.) In addition, G6's declarations in support of its burden argument are not particularly helpful to the Court's analysis. Neither declaration is based on Plaintiff's requests and instead rely on search terms used in G6's response to a Motion to Compel filed in a District of New Mexico TVPRA case, 1:23-CV-00879, ECF No. 60. (ECF Nos. 209-12, 209-13.) As G6's proportionality argument is not related to Plaintiff's requests, the Court finds that G6 has failed to meet its burden of showing how Plaintiff's requests are unduly burdensome.

C. Specific Requests

Plaintiff includes a number of specific discovery requests in her Motion. (Mot. at PageID 3661–62.) The Court declines to evaluate each request. The parties are DIRECTED to meet and confer regarding those requests. The Court expects the parties to utilize its Order in H.H., ECF No. 185 and M.A., ECF No. 320 as a starting point for their discussions. In addition, the Court expects the parties to reach an agreement on appropriate search terms without the Court's intervention.

IV. CONCLUSION

*5 For the foregoing reasons, Plaintiff's Motion to Compel (ECF No. 206) is GRANTED in part. The Court ORDERS the following:

IT IS SO ORDERED.

Date: January 17, 2025 /s/ Elizabeth A. Preston Deavers__________

ELIZABETH A. PRESTON DEAVERS UNITED STATES MAGISTRATE JUDGE