Second Amended Complaint: Borys, et al. v. Ballard and Aerial Recovery — Overview
A Second Amended Complaint filed in the United States District Court for the District of Utah alleges violations of the Trafficking Victims Protection Reauthorization Act (TVPRA) against Tim Ballard and Aerial Recovery by multiple plaintiffs.
Parties and Legal Basis
The plaintiffs include Celeste Borys, Mary Hall, Sashleigha Hightower, Krista Kacey, Kira Lynch, and Bree Righter.
The defendants are:
- Timothy Ballard
- Aerial Recovery
The complaint invokes federal jurisdiction under 18 U.S.C. §§ 1589 and 1591, alleging forced labor and sex trafficking through force, fraud, or coercion.
Core Allegations
The complaint alleges that:
- Plaintiffs were recruited to participate in a tactic referred to as the “Couples Ruse”
- Defendants obtained labor and services through fraud, coercion, and psychological pressure
- Plaintiffs were led to believe that failure to participate would result in harm to trafficked women and children
The filing asserts that this constituted a “scheme, plan, or pattern” designed to compel participation under federal trafficking statutes.
“Couples Ruse” Description
According to the complaint:
- The “Couples Ruse” involved male and female operatives posing as romantic partners during undercover operations
- Plaintiffs allege they were required to engage in sexualized conduct as part of these roles
- The complaint states that such conduct included simulated or actual sexual activity in exchange for perceived operational value
The filing characterizes this conduct as part of the alleged trafficking scheme.
Allegations of Coercion and Grooming
The complaint alleges that:
- Plaintiffs were psychologically groomed through appeals to religion, mission purpose, and personal significance
- Ballard allegedly invoked spiritual authority, including claims of divine approval and religious endorsement
- Plaintiffs were told they were uniquely chosen and necessary to save victims
The filing further alleges that:
- Participants were isolated from others
- Required to sign non-disclosure agreements
- Instructed not to discuss operations with colleagues or family
Allegations of Sexual Misconduct
The complaint alleges that:
- Plaintiffs were subjected to escalating sexual demands framed as necessary for operational success
- Sexual contact was presented as required to maintain cover or ensure safety
- Some plaintiffs allege unwanted sexual advances, assault, or coercive sexual conduct
These allegations are presented as part of the broader trafficking and forced labor claims.
Fraud and Misrepresentation
The filing asserts that:
- Plaintiffs were recruited under the representation that they would participate in legitimate anti-trafficking operations
- The operations were allegedly fabricated or misrepresented
- Defendants used Ballard’s background, public reputation, and connections to gain trust
It further alleges that:
- Plaintiffs were not properly trained
- Operations lacked legitimate law enforcement structure
- Representations made to participants did not reflect actual activities
Organizational and External Influences
The complaint includes allegations that:
- The formation and promotion of Operation Underground Railroad (O.U.R.) were tied to religious and public relations objectives
- Influential individuals and donors supported the organization’s development
- Public narratives and media projects were used to build Ballard’s profile
These claims are presented as part of the broader context of recruitment and public representation.
Plaintiff Accounts
The complaint includes detailed individual accounts describing:
- Recruitment into operations
- Training involving sexually suggestive scenarios
- Participation in domestic and international travel
- Experiences of fear, confusion, and pressure to comply
Plaintiffs allege that:
- They were led to believe lives were at stake if they refused participation
- They lacked resources or ability to leave operations independently
- Their personal relationships, finances, and well-being were negatively affected
Additional Allegations
The complaint further alleges:
- Use of psychic guidance in operational decision-making
- Internal awareness of misconduct by associates
- Continued association between Ballard and affiliated organizations after prior complaints
Legal Claims
The plaintiffs assert claims under federal law, including:
- Forced labor (18 U.S.C. § 1589)
- Sex trafficking (18 U.S.C. § 1591)
They seek:
- Compensatory damages
- Punitive damages
- Attorneys’ fees and other relief
Conclusion
The Second Amended Complaint presents extensive allegations that Tim Ballard and Aerial Recovery engaged in a coordinated scheme involving coercion, fraud, and sexual exploitation under the guise of anti-trafficking operations.
All claims outlined in the filing are allegations made by the plaintiffs and have not been adjudicated in court.
