Cozen O’Connor: Sanctuary Pro Bono Partner Spotlight

Romy Felsen-Parsons

A spotlight on Sanctuary Pro Bono Partner Cozen O’Connor for their team’s outstanding work in assisting an incarcerated domestic violence survivor on her DVSJA application and helping secure her release.

Sanctuary for Families’ Pro Bono Project has the honor of working with hundreds of extremely dedicated and expert pro bono attorneys per year. As part of our new Pro Bono Spotlight, we’ll be highlighting some of the great work done by Sanctuary pro bono attorneys!

*Please note that this blog contains descriptions of physical and sexual abuse that could be triggering*

Cozen O’Connor Team Help Secure Freedom for Incarcerated Domestic Violence Survivor

We are thrilled to share that another one of Sanctuary’s Incarcerated Gender Violence Survivors Initiative clients, Ms. S, has been released due to the outstanding efforts of a Cozen O’Connor team headed by Members Matthew L. Elkin and Emily Shoor. Matt and Emily, along with their team, spent three years working on Ms. S’s DVSJA resentencing motion, which was approved in March 2023.

After a Domestic Violence Survivors Justice Act (DVSJA) resentencing motion granted in March of 2023, Sanctuary’s client, Ms. S, was released after more than 10 years of incarceration for the stabbing death of her severely abusive former intimate partner. Without DVSJA resentencing, she would have served nearly 15 more years for her manslaughter conviction, in which she stabbed her abuser after he broke into her home in the middle of the night, threw her against a wall, and began to strangle her. We are deeply grateful to Matt Elkin and Emily Shoor from Cozen O’Connor for investing hundreds of hours into securing freedom for this survivor.

Like many incarcerated women, Ms. S has been subjected to unconscionable levels of abuse throughout her life, both at the hands of intimate partners and family members. Former partners have subjected her to severe sexual and physical violence, trafficking, forced drug usage, and repeated threats to her life with guns and violence.

The abuse perpetrated by Mr. B, the partner whose death led to Ms. S’s incarceration, began almost immediately after they started dating and escalated rapidly to severe physical, sexual, and psychological abuse. On multiple occasions he strangled Ms. S to the point of unconsciousness. He was jealous and controlling, and would frequently yell at Ms. S in public, break her things, and humiliate her. The abuse she suffered put Ms. S at a significantly high risk of femicide at the hands of her abuser. Under Dr. Jacquelyn Campbell’s widely used Danger Assessment, an escalation of violence, strangulation, sexual assault, violent jealously, and control are all indicators of an increased risk of lethality.

At great risk to her safety, Ms. S left Mr. B and began to implement an exit strategy, changing the locks of her doors, telling family and friends to keep Mr. B away, and planning to move to a new apartment.

However, the day before Ms. S was scheduled to move, she woke up to find Mr. B standing over her, having broken into her apartment. Mr. B attacked Ms. S, throwing her against a wall and strangling her. To protect herself, Ms. S grabbed a nearby sharp object and stabbed Mr. B once. The blow was not intended to be fatal – in fact, Ms. S immediately began conducting CPR on Mr. B, and she did not know that Mr. B had died until the police revealed it to her in questioning.

This history of domestic violence and the circumstances surrounding Mr. B’s death were never raised at trial. Ms. S was acquitted of second degree murder but convicted of manslaughter in the first degree and given the maximum sentence of 25 years.

In her ten-plus years of her incarceration, Ms. S has worked hard to heal from her trauma, taking nonviolent conflict resolution courses and aggression replacement training. She has thrived academically and professionally, holding several jobs at the prison while completing her Associate’s and Bachelor’s Degree, as well as a writing course and a Basic Legal Research and Law Library Management course. During this time, Ms. S also reached out to Sanctuary for legal assistance. After hearing her story Sanctuary recruited the law firm of Cozen O’Connor to help Ms. S, and Cozen O’Connor Members Matt L. Elkin and Emily Shoor agreed to represent Ms. S pro bono on her DVSJA application.

We reached out to Emily and Matt to hear more about their experience working with Ms. S.

What made you want to take on Ms. S’s case? What was your experience like working with her?

Matt: It was very clear from the beginning that Ms. S had lived a really tragic life and tragic circumstances led to her incarceration, but she still had such a positive attitude about her. We could tell that on a day-to-day basis she struggled to maintain [this attitude], day after day and week after week and year after year in Bedford Hills where things didn’t get any better, but she always kept up hope and was enthusiastic to work with us, which made her a tremendous client to work with.

What do you find compelling about DVSJA resentencing cases, as opposed to other cases with incarcerated survivors? What unique challenges and opportunities do they present?

Emily: I think it’s really wonderful that the [DVSJA] legislation opened the door for so many people to seek resentencing for circumstances that weren’t originally considered at their sentencing hearings. Ms. S was serving the maximum sentence for the crime of manslaughter, 25 years. And the DVSJA maximum sentence is only 5 years. So it gives people an opportunity to get their lives back, which is really compelling all on its own.

Which moment in your representation was the most impactful for you?

Matt: The obvious moment is when we were in court, after the judge ordered resentencing, listening to Ms. S express her gratitude to everyone who had a role in her resentencing for giving her this chance to ger her life back . On top of this, Ms. S was resentenced on a Thursday afternoon in Rochester and we were under the impression that she wasn’t going to be able to get out of prison before the weekend because she was incarcerated at Bedford Hills in Westchester. This was one of those things that we’d prepared ourselves and Ms. S for as an unfortunate reality. But that didn’t stop us from trying, and we asked the Judge if she could try to motivate [the Department of] Corrections to get things moving, and then everyone really sprang into action. The DA’s office supported our request; one of the guards who transported Ms. S from prison before the hearing approached the bench and explained the logistics of prisoner transport; the Judge’s law clerks were on the phone with their contacts at DOCCS before the hearing even ended; the team from Willow [Domestic Violence Center] was calling politicians and asking everyone they knew for support. Watching the entire community rally around Ms. S was particularly impactful. She was out of prison by lunchtime the next day, much to everyone’s surprise.

Emily: Also, the assistance that we got from the Monroe County DA, Sandra Doorley and from ADA Patrick Gallagher was amazing. DA Doorley was open minded and agreed to meet with us so we could discuss Ms. S’s case and advocate on her behalf directly. It also gave us the opportunity to “introduce” Ms. S to DA Doorley, by allowing us to convey Ms. S’s story beyond the words on paper. Once the DA’s office consented to the re-sentencing application, their cooperation and assistance proved invaluable. It’s such a unique experience in court to have both sides working to achieve the same result, and the Judge was clearly moved by the cooperation between both sides. It was really the most joyous a criminal courtroom could be.

Anything else you want to mention?

Emily: I’m really grateful to Sanctuary for partnering with firms to give attorneys the opportunity to do this kind of work in conjunction with their mentorship and expertise. Without the IGVSI team, Kayla, Ross, and Isabelle, we would not have been able to do this.

Matt: I also really value the pro bono program at Cozen O’Connor because members of our team were able to devote hundreds and hundreds of hours to this case. If not for a firm that’s truly committed to pro bono work, we would not have been able to devote the resources we needed to preparing Ms. S’s application, visiting her in prison multiple times, and ultimately going up to Rochester to get her resentenced. A lot of law firms talk the talk about pro bono work, but Cozen O’Connor has proven itself as a real leader.

We are so grateful to Emily, Matt, and Cozen O’Connor, and thrilled to welcome Ms. S home!

Join the Cozen O’Connor team in standing with our clients. Your gift supports Sanctuary’s life-saving work with survivors of gender violence.

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Wilson Sonsini: Sanctuary Pro Bono Partner Spotlight

Romy Felsen-Parsons

Sanctuary has had the pleasure of partnering with talented Wilson Sonsini professionals on matters ranging from uncontested divorces to parole preparation for incarcerated survivors to asylum cases to immigration relief for survivors of trafficking.

Sanctuary for Families’ Pro Bono Project has the honor of working with hundreds of extremely dedicated and expert pro bono attorneys per year. As part of our new Pro Bono Spotlight, we’ll be highlighting some of the great work done by Sanctuary pro bono attorneys!

*Please note that this blog contains descriptions of physical and sexual abuse that could be triggering*

Since first partnering with Sanctuary in 2016, law firm Wilson Sonsini Goodrich Rosati (WSGR) has become a steadfast supporter of survivors of gender-based violence through its truly robust and diverse pro bono practice. In the last year alone, Wilson Sonsini attorneys contributed over 2,000 pro bono hours, making the firm one of our top ten most active pro bono partners. Sanctuary has had the pleasure of partnering with talented Wilson Sonsini professionals on matters ranging from uncontested divorces to parole preparation for incarcerated survivors to asylum cases to immigration relief for survivors of trafficking. We are deeply grateful for their support and excited to highlight some recent successes Wilson Sonsini’s teams have secured for survivors.

Parole preparation, Ms. M 

Associates Alexia Syrmos and Fran Jennings, and partner Chul Pak recently worked with an incarcerated survivor, Ms. M, as she was approaching her appearance before the Parole Board. Ms. M was granted parole in February and released to be with her family this past March.

Ms. M was serving a 5-year sentence, lowered from the original 15 years, for fatally stabbing her ex-husband with a knife when he and two other people attacked Ms. M and her then-girlfriend in the street. Ms. M’s traumatic experiences of domestic violence at the hands of her ex-husband were never discussed at the time of the plea.

As previous blog posts have mentioned, in New York State, incarcerated individuals are not entitled to legal representation in their parole hearings. The burden falls entirely upon them to convey their remorse and rehabilitation, while simultaneously discussing a highly traumatic incident in their lives and responding to difficult questions from the Parole Board. As such, Sanctuary has been partnering with law firms to prepare individuals in advance for their parole hearings, both by conducting mock interviews and by putting together parole packets advocating for the client’s release.

We reached out to Alexia, Fran, and Chul to hear about their experiences working with Ms. M on this case. Alexia responded, “Working with Ms. M has, without any reservation whatsoever, been the highlight of my legal career. Ms. M is one of the kindest, most thoughtful individuals that I’ve ever had the privilege to meet. Throughout the entirety of this process—a deeply personal, uncertain, and painful one—Ms. M was a beacon of hope. Even over the phone, you could feel positivity radiating off of her. Ms. M is the sort of person who can find a silver lining in everything. She’s always so quick to laugh and extend grace to others, no matter the circumstance.” Alexia noted that she is “beyond excited to see the things that Ms. M accomplishes in the next few years.”

Publication divorce, Ms. B

Associates Zak Kravat and Adam Toporovsky, now an Assistant U.S. Attorney, recently successfully obtained a publication divorce for their client, Ms. B, from her physically and verbally abusive ex-husband. Matrimonial cases provide our clients with critical relief in the form of severing legal ties from their abusers. Publication divorces are a slightly unusual form of an uncontested divorce (a divorce in which there are no issues to be litigated) in that, as a client’s spouse cannot be physically located, the legal team must file a motion requesting that the court allow service of the divorce papers by publication in a newspaper. Staff at Wilson Sonsini, especially Zak, have been incredibly generous with their time and energy on these types of matrimonial cases and have built significant expertise in this area.

“I have been fortunate to work with at least 100 different pro bono attorneys during my time here at Sanctuary for Families. Though they have all been memorable and I’ve been very appreciative of all of the individual pro bono attorneys, I must say it’s been a singular and distinctive honor working with Zak on the multiple cases he’s worked on (at least half a dozen off the top of my head). Even if the case became very complicated and lengthy, he never complained or gave up. He’s been determined, legally creative, and treats each client with the utmost respect, patience, and warmth. It’s a pleasure and honor to work with Zak. I wish I could award him an even greater honor and recognition of all he means to us here at Sanctuary. Thank you Zak.”

Francisco Santiago
Deputy Director, Matrimonial/Economic Justice Project

T-Adjustment of Status, Ms. R 

This February, Sanctuary’s client, Ms. R, received word from U.S. Citizenship and Immigration Services (USCIS) that she had been granted a green card and had officially become a Lawful Permanent Resident. As a survivor of trafficking who assisted law enforcement in the investigation of her trafficker, Ms. R had been eligible for T nonimmigrant status (also known as a T visa). Wilson Sonsini Senior Counsel Jason Mollick headed the pro bono team that represented Ms. R on her T-visa case, with the assistance of Justin Cohen, former associate at WSGR and current litigation counsel at Google (and devoted member of Sanctuary’s Pro Bono Committee!). When Ms. R became eligible to adjust her status, Jason continued to work with her, ultimately helping her to obtain her green card. Jason has worked extensively on cases with Sanctuary’s Anti-Trafficking Initiative, representing clients not only on their Adjustment of Status cases, such as this one, but with the manifold other legal issues that arise for trafficking survivors, such as by filing motions to vacate criminal charges and on applications for employment authorization documents so that survivors can work legally.

Jason reflects, “Working with Ms. R has been one of the most rewarding and satisfying parts of my career. We not only assisted her in attaining valid legal status, but also witnessed first-hand how legal assistance can help someone rebuild their life, start a family, and secure a future. It has been an honor to partner with Sanctuary for Families in this task.”

Director of Sanctuary’s Anti-Trafficking Initiative Jessica-Wind Abolafia writes, “Over a period of seven years, Jason Mollick led a team that not only helped Ms. R and her husband to obtain T visas, but successfully represented Ms. R as a victim witness in a federal investigation, vacated her criminal convictions in two states and four jurisdictions, and assisted her and her husband to secure lawful permanent residency – ensuring unity and permanency for Ms. R and her family. Jason’s dedication, compassion, attention to detail, supervision of the team and trauma informed practice is exemplary.”

“I thought for a long time there was no justice. When I met the team they really tried to make me feel comfortable. With everything going on in the world, they made me feel safe to apply for immigration status and to trust in the system. I felt supported. I am so grateful for what they did for me and my husband. I have returned to feel that yes, there is justice.”

– Ms.R, Sanctuary Client

We are deeply grateful to the Wilson Sonsini staff who have supported our work, both the people briefly mentioned in this post and so many others who have also been instrumental in assisting survivors of gender-based violence. We look forward to our continued partnership!

Join the Wilson Sonsini team in standing with our clients. Your gift supports Sanctuary’s life-saving work with survivors of gender violence.

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Cleary Gottlieb: Sanctuary Pro Bono Partner Spotlight

Romy Felsen-Parsons

Sanctuary teamed up with Cleary Gottlieb to submit an amicus brief highlighting how Florida’s proposed 15-week abortion ban would disproportionately endanger survivors of intimate partner violence.

Sanctuary for Families’ Pro Bono Project has the honor of working with hundreds of extremely dedicated and expert pro bono attorneys per year. As part of our new Pro Bono Spotlight, we’ll be highlighting some of the great work done by Sanctuary pro bono attorneys!

*Please note that this blog contains descriptions of physical and sexual abuse that could be triggering*

Florida’s House Bill 5 (HB 5) is the latest in a string of proposed state laws restricting access to safe abortions and reproductive care. This controversial bill, which proposes a ban on abortion after 15 weeks of pregnancy, is currently before the Florida Supreme Court—the highest state court in Florida— in the case of Planned Parenthood Southwest and Central Florida v. Florida. This law, like any law curtailing reproductive rights, gives abusers another powerful tool by which to control their victims. Sanctuary’s Reproductive Rights Working Group, co-chaired by Sanctuary attorneys Anne Glatz and Luba Reife, recently teamed up with Cleary Gottlieb to submit an amicus brief highlighting the danger this proposed ban would disproportionately pose to survivors of intimate partner violence (IPV). We reached out to authors Jennifer Kennedy Park, Sarah Gutman, Lilianna Rembar, and Caroline Soussloff—all of whom are Floridian or have Floridian family members themselves—to learn what participating in this project meant to them.

Partner Jennifer Kennedy Park explained, “I was raised in Florida and still have family living there so I was horrified at the passage of HB5.  … Since the Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, we’ve seen the terrible impact of the reversal of Roe v. Wade.  As we feared, states are passing increasingly restrictive and dangerous bans on abortion—with no regard for women’s lives, health or autonomy. I personally, along with thousands of other law firm partners, committed to fighting for reproductive freedom in a call to action in the American Lawyer that, to date, more than 2,650 women partners from nearly 200 law firms have signed on. This brief is part of that commitment.” Associate Sarah Gutman added, “Abortion bans like Florida’s HB5 harm all people, but the devastating consequences will fall heaviest on those who are already the most marginalized. That’s why it’s so important for all of us—including law firms—to work to protect and expand access to abortion. It can literally be a lifesaver.”

While clear logical links exist to suggest that pregnant people in abusive relationships will be disproportionately impacted by such legislation – for example, the fact that many abusers attempt to restrict their partner’s birth control options as a means of imposing control and restricting their bodily autonomy – the statistics nonetheless are truly staggering. Women who have experienced IPV are nearly three times more likely to report that their partner made it difficult to use birth control, increasing the risk of an unwanted pregnancy. Sarah Gutman noted, “I was particularly glad that [the amicus brief] highlights the links between gender-based violence (GBV) and denial of abortion access.  Abortion bans and GBV are different sides of the same coin—both are attacks on bodily autonomy.  They create barriers to full social, economic, and political equality regardless of gender.” As the amicus brief explains, in addition to facing universal barriers to care, such as financial restrictions, etc., pregnant victims of IPV are frequently subjected to harassment, surveillance, intimidation, or interference by their abusive partners while attempting to access reproductive health services. Research also shows that pregnant people subjected to GBV are more likely to seek abortion or prenatal services later into their pregnancy than others. Given that most people do not know that they are pregnant until six or seven weeks into the pregnancy, a ban at 15 weeks would force a survivor of IPV to consider their options and make all necessary arrangements to overcome these challenges in a very short period of time. Associate Lilianna Rembar adds, “Forcing pregnant Floridians to carry unwanted pregnancies to term, the 15-week ban will especially harm victims of gender-based violence who face physical, psychological, and financial adversities, along with other barriers to obtaining abortions.”

“Forcing pregnant Floridians to carry unwanted pregnancies to term, the 15-week ban will especially harm victims of gender-based violence who face physical, psychological, and financial adversities, along with other barriers to obtaining abortions.”

-Lilianna Rembar, Associate

Due to sexual violence or reproductive coercion, IPV increases the risk of unplanned and unwanted pregnancies, which in turn increase the risk and severity of IPV. Resulting pregnancies from these abusive relationships threaten to create lifelong legal ties tethering the victim to their abuser and are often used as tools of control themselves. Additionally, pregnancy places victims of IPV at severely heightened risk of an escalation of physical violence: Femicide is the leading cause of death for pregnant and post-partum women in the United States, which has the highest maternal mortality rate among high-income countries. Pregnant and postpartum women in the United States are more than twice as likely to die by homicide than by any other cause. Associate Caroline Soussloff reflected, “I was galvanized to learn that the leading cause of death in pregnant women in the United States is homicide—I hope that Florida’s judges and politicians will be too. I hope that fact, and the other data and stories included in our brief, will help to root their decision-making in the experiences of the one in four American women who obtain abortions.”

“The pro bono team from Cleary Gottlieb exceeded expectations at every step of the process. Faced with a very short deadline, the Cleary team immediately jumped into action and impressed us with their keen insights and erudite, nuanced grasp of the issues. The end result was a compelling and highly persuasive brief that concisely but thoroughly illustrated the impact of reproductive rights restrictions for survivors and victims of gender-based violence in general, and the impact of HB5 on Floridians subjected to GBV in particular.”

Anne Glatz
Senior Staff Attorney, Sanctuary for Families

We are incredibly grateful to Cleary Gottlieb for representing Sanctuary for Families in this advocacy. The brief, which was submitted on March 9, was signed by organizations and individuals including Legal Momentum, The National Organization for Women Foundation, The Rapid Benefits Group Fund, Women for Abortion and Reproductive Rights, Margaret A. Baldwin, JD, Professor Cyra Choudhury, Professor Donna K. Coker, Professor Zanita E. Fenton, Doctor Kathryn M. Nowotny, PhD, and Jodi Russell. We are thrilled to work in collaboration with these outstanding individuals and organizations and are committed to conducting continued advocacy from the perspective of GBV service providers as the reproductive rights landscape continues to change in dangerous ways for survivors.

Join the Cleary team in standing with our clients. Your gift supports Sanctuary’s life-saving work with survivors of gender violence.

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Tushna Gamadia: Sanctuary Pro Bono Partner Spotlight

Sanctuary for Families

A spotlight on Sanctuary Pro Bono Partner Tushna Gamadia and her outstanding work representing survivors of gender-based violence for over 16 years.

Sanctuary for Families’ Pro Bono Project has the honor of working with hundreds of extremely dedicated and expert pro bono attorneys per year. As part of our new Pro Bono Spotlight, we’ll be highlighting some of the great work done by Sanctuary pro bono attorneys!

*Please note that this blog contains descriptions of physical and sexual abuse that could be triggering*

Few could rival Tushna Gamadia’s dedication and generosity in providing her time, brilliant advocacy, and support to survivors of gender-based violence. Tushna, Of Counsel at Morrison & Foerster LLP for almost ten years and former associate at Cadwalader, Wickersham & Taft LLP for eleven years, has been contributing to Sanctuary’s mission for an astounding sixteen years. During this time, Tushna’s representation of survivors has truly run the gamut, from uncontested divorces to name changes to an array of immigration matters such as asylum, SIJS, U-visas, VAWA self-petitions, and adjustment of status cases. Simultaneously, she has been a long-time member of Sanctuary’s Pro Bono Council (PBC), an ardent supporter of Sanctuary’s holiday Adopt-a-Family and gift card programs, as well as a steadfast volunteer at Sanctuary’s annual Above & Beyond Awards ceremony and Zero Tolerance benefit. Tushna has consistently answered the call to action to support Sanctuary and survivors of gender-based violence in whatever way she can. It is our pleasure to highlight Tushna for this month’s Pro Bono Spotlight.

In her non-pro bono work, Tushna is a real estate lawyer who notes that her favorite part of work is spending all day interacting with people—be it clients, colleagues, or nonprofit service providers.

“I have always believed there should be equal justice and access to the law for everyone, not just if you’re fortunate enough to be able to afford a lawyer. That is part of the reason I became a lawyer in the first place.”

-Tushna Gamadia

On why she works with survivors of gender-based violence, Tushna explains, “I have been so inspired by my pro bono clients. They have such courage; they refuse to give up despite having been through so much, literally through hell and back oftentimes. They keep believing that if they just persist and work at it they can make a better life for themselves and for their children. I want to work with people like that, whom I learn from and whom I consider role models.” Tushna notes that despite frequent language barriers, trauma, and the stress of juggling childcare with making a living, her clients have always been gracious, found ways of communicating effectively, and shared with her their senses of humor and their stories.

Tushna Gamadia

In one memorable case, Tushna represented a teenage girl in her Special Immigrant Juvenile Status (SIJS) proceeding and witnessed her client recount the years of abuse and neglect she had experienced to the judge. Tushna recalls how stoic and steadfast this young client had been throughout the preparation of the case, but how she finally broke down for the first time during trial when faced with compassion from the judge. Despite everything she had endured, she was determined to go to college, get a job, have an apartment, and live an independent and fulfilled life. According to Tushna, it was one of the happiest moments of her life when the judge in Bronx Family Court granted the client’s petition and issued an Order finding her eligible for SIJS and appointing her former stepmother her guardian. Based on those findings, the United States Citizenship and Immigration Service granted the client permanent residence and she was able to remain in the U.S. and achieve her goal of graduating from college..

Incredibly, Tushna’s work with Sanctuary is not the only pro bono work she does. Pre-pandemic, Tushna was a regular participant in the New York City Family Court Volunteer Lawyer Program since 2014, helping pro se litigants understand their cases and advising them on their next steps, and during the height of the Covid crisis, Tushna led Morrison Foerster’s Real Estate Group’s participation in the Small Business Legal Relief Alliance, counseling clients primarily on their rights and obligations under their leases and how to negotiate with their landlords.

Says Jennifer Brown, Senior Pro Bono Counsel at Morrison Foerster, “The breadth of Tushna’s concerns and commitments was vividly illustrated when she won MoFo’s firmwide pro bono award in 2020—an award which is given to only one attorney per year. The award includes directing a $10,000 donation from our firm’s foundation and Tushna asked that the funds be shared by four organizations, including Sanctuary.”

“It has been my absolute privilege to work with and get to know Tushna during my time at Sanctuary. I am frequently inspired by the depth of her compassion and the amazing, trauma-informed lawyering she provides to our clients. And she’s just generally a kind and wonderful person to know!”

Nicole Fidler
Director, Sanctuary for Families’ Pro Bono Program

In her free time, Tushna enjoys taking long walks with her dogs, being out on the water and outdoors generally, and reading and cooking.

We are so grateful to Tushna for her incredible work on behalf of survivors.

Join Tushna in standing with our clients. Your gift supports Sanctuary’s life-saving work with survivors of gender violence.

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