All Claims Dismissed in NCOSE-Sponsored 'Trafficking' Suit Against Several Adult Studios

All Claims Dismissed in NCOSE-Sponsored 'Trafficking' Suit Against Several Adult Studios

LOS ANGELES — All claims made by a Jane Doe plaintiff against several adult studios, in a lawsuit sponsored by religiously motivated anti-porn lobby NCOSE — formerly “Morality in Media” — were dismissed last month, court records show.

On Aug. 19, the Jane Doe plaintiff and defendants Diabolic Video Productions Inc., Black Ice LTD, Zero Tolerance Entertainment Inc. and Third Degree Films filed a joint motion to dismiss all of the claims “with prejudice,” meaning they cannot be refiled.

Typically, these types of joint motions are the result of a deal or settlement having been reached out of court, legal experts told XBIZ.

San Diego judge Michael M. Anello granted the joint dismissal motion in an Aug. 24 order.

As XBIZ reported, in March 2021, in an unusual decision, Anello ruled that, although the contracts signed by a former performer were valid, the arbitration agreements that were part of them should be disregarded and the lawsuit could move forward.

A Lawsuit Much Ballyhooed by NCOSE

According to the complaint Doe filed with the aid of anti-porn lobby NCOSE, she briefly worked in the adult industry around 2009-2010. At the time, she alleges, she was represented by someone named Cissy Steele, aka Cissy Gerald, a person claiming to be an adult modeling agent.

Doe claimed that her relationship with Steele, who is cited a main co-defendant, would fall under the definition of “human trafficking.”

The complaint also named a number of adult studios and sites active a decade ago as co-defendants on the basis that they distributed scenes allegedly featuring the Jane Doe.

The lawsuit was promoted worldwide by NCOSE as a landmark moment in the anti-porn crusade the group has been waging since the early 1960s. In September 2020, NCOSE issued a press statement headlined “NCOSE Law Center Files First Ever Anti-Trafficking Lawsuit Against Pornography Producers on Behalf of Survivor.” The item was picked up by mainstream outlets and also disseminated by NCOSE’s fellow War on Porn advocacy groups.

The suit alleged that the studios “were instrumental in knowingly aiding, abetting, facilitating and participating in Steele’s sex trafficking scheme, while knowing, or in reckless disregard of the fact, that she would use means of force, fraud, and/or coercion to force Jane Doe into engaging in commercial sex acts in violation of the Trafficking Victims Protection Reauthorization Act (‘TVPRA’).”

“Our clients had nothing to do with the alleged sex trafficking that occurred over a decade ago,” the studios’ attorney Jonathan Brown, of Buffalo, New York law firm Lipsitz Green Scime Cambria, told XBIZ at the time of the March 2021 ruling.

Copyright © 2026 Adnet Media. All Rights Reserved. XBIZ is a trademark of Adnet Media.
Reproduction in whole or in part in any form or medium without express written permission is prohibited.

More News

Lucy Mochi Makes Her Blacked Raw Debut

Lucy Mochi has made her debut for Vixen Media Group studio imprint Blacked Raw, alongside Jason Luv.

Jonni Darkko Drops New Evil Angel DP Release With Anissa Kate

Anissa Kate stars with Musa Phoenix and Hollywood Cash in a new Jonni Darkko-helmed Evil Angel scene.

Kasey Kei, Bella Joie & Hazel Grace Star in Latest From Transfixed

Kasey Kei, Bella Joie, and Hazel Grace star in the latest release from Transfixed, titled "Ex-Couple’s Massage."

Ivy Ireland, Derek Kage Front Latest From Pure Taboo

Ivy Ireland and Derek Kage star with Parker Ambrose in the latest release from Pure Taboo, titled "Unnatural Arrangement."

Octavia Red Makes Her Blacked Debut

XMA winner Octavia Red has made her debut for Vixen Media Group studio imprint Blacked, alongside Hollywood Cash.

Hazel Heart Leads Latest From Kink.com

Hazel Heart stars in the latest installment of Kink.com's "KinkVR" series, titled "Tied-Up & Tormented."

Dorcel Drops Franck Vicomte's 'PL4Y #4'

Dorcel has released director Franck Vicomte’s latest feature, “PL4Y #4.”

Paisley West Makes Her WIFEY Debut

Paisley West has made her debut for Vixen Media Group studio imprint WIFEY alongside her husband Justin and Dan Damage.

Linda Lan Performs 1st Studio DP in Jonni Darkko's Latest 'Double Penetration Fixation'

Linda Lan performs her first studio DP and toplines the sixth volume of multi-XMAs winner Jonni Darkko's “Double Penetration Fixation,” from Evil Angel.

Codi Vore, Girthmasterr Star in Latest From Brazzers

Codi Vore stars with Brazzers exclusive Girthmasterr and Kaiia Eve in the studio's latest release, "Penthouse or Bust!"

Show More