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Jurisdiction – Forum non conveniens

U.S. District Court

Mass. Lawyers Weekly Staff//February 12, 2026//

Jurisdiction – Forum non conveniens

U.S. District Court

Mass. Lawyers Weekly Staff//February 12, 2026//

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Where a defendant has moved to dismiss claims of human trafficking and conspiracy, that motion should be allowed because (1) an adequate alternative forum is available and (2) considerations of convenience and judicial efficiency strongly favor litigating the claim in that alternative forum.

“This case arises from claims of human trafficking and conspiracy brought by plaintiff, Scarlett Pavlovich (‘plaintiff’ or ‘Pavlovich’), against Amanda Palmer (‘defendant’ or ‘Palmer’), the former wife of her alleged abuser, Neil Gaiman (‘Gaiman’) …

“… Pavlovich is a citizen of New Zealand and resided therein during the relevant time period. Palmer is a U.S. citizen who was lawfully domiciled in New Zealand during the relevant time period. …

“The fact that plaintiff’ s claim in New Zealand would be handled outside of the judicial system does not necessarily mean New Zealand is an inadequate forum. Indeed, courts have consistently found New Zealand (and many other countries with similar adjudicative remedies) to be adequate alternative forums notwithstanding the lack of formal court proceedings. …

“… Plaintiff is a citizen of New Zealand, all the underlying conduct took place in New Zealand and defendant was a lawful resident of New Zealand during the relevant time period. Common sense dictates that New Zealand is the more interested forum. …

Pavlovich v. Palmer (Lawyers Weekly No. 02-066-26) (13 pages) (Gorton, J.) (Civil Action 25-10263-NMG) (Feb. 6, 2026).

Click here to read the full text of the opinion.

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