In Loving Memory of Narkis Golan

Our statement on the passing of Sanctuary client Narkis Golan — survivor, relentless advocate, and devoted mother to Bradley.

All of us at Sanctuary for Families are heartbroken about the passing of one of our beloved clients, Narkis Golan. The devoted thirty-two-year-old mother of a six-year-old boy, Narkis died unexpectedly last week, in the middle of a legal battle to prevent her little boy, Bradley, from being sent back to Italy where she had been severely abused by his father, frequently in Bradley’s presence.

Even though the federal court judge presiding over the Hague Convention case brought by the father to force Bradley’s return to Italy had found, by clear and convincing evidence, that returning the child would constitute a grave risk of harm because of the pattern of severe domestic violence perpetrated by his father against his mother, the judge ordered Bradley’s return. That decision was appealed to the US Supreme Court, where Narkis prevailed unanimously on the issue of whether the judge was required to consider ameliorative measures that could protect Bradley’s safety in Italy. This Supreme Court decision constitutes an important legal victory that advances the rights of survivors in Hague cases nationally. Disappointingly, when the case was sent back down to the federal court judge, she inexplicably again ordered Bradley’s return to Italy. Although dismayed by the order, Narkis worked assiduously with her attorneys to overturn it, determined to protect Bradley’s safety. Just three hours before her death, she was speaking with her lawyers about the appeal.

Narkis and Bradley

With her family’s permission, we have spoken to reporters at Jezebel and NBC News about Narkis’s passing. We are comforted that Narkis’s voice continues to be heard and her heroic battle to protect her son is being recognized and honored. Please know that we are identifying additional ways to honor Narkis and her legacy and are working closely with her family members to ensure that Bradley is protected.

Our deepest gratitude to all who worked tirelessly on Narkis‘s case and accompanied Narkis in her pursuit of justice: Sanctuary board member and Paul Weiss partner Claudia Hammerman, who led the legal team at Paul Weiss that litigated the case tirelessly and brilliantly; Sanctuary pro bono partner and Morvillo Abramowitz partner Karen R. King, who argued the case of Golan v. Saada before the Supreme Court; Sanctuary staff, especially Nicole Fidler, Ruchama Cohen, and Lisa Vara; and all of the outstanding attorneys at Paul Weiss and Morvillo Abramowitz who worked on this case for more than three years.


Our Statement on the Supreme Court’s Abortion Decision

The Court’s decision to overturn Roe v. Wade ignores 50 years of precedent and is a blatant attack on human rights.

Hon. Judy Harris Kluger, Executive Director of Sanctuary for Families, issued the following statement in response to the U.S. Supreme Court decision in Dobbs v. Jackson Women’s Health Organization:

“Today’s Supreme Court’s decision, decided largely on ideological lines, to overturn Roe v. Wade and Casey ignores 50 years of precedent and is a blatant attack on human rights. Many states are now free to impose bans on abortion with no exceptions, even for rape and incest. The three judges in the minority eloquently wrote that they dissent ‘with sorrow — for this Court, but more for the many million American women who today have lost a fundamental constitutional protection.’

Like domestic violence, abortion bans are about power and control. In allowing states to restrict women from accessing abortion, the Court is stripping away their bodily autonomy — leveraging its power to force women to carry unwanted, unsafe, or unviable pregnancies to term with utter disregard for what that means to their rights as equal citizens of this nation. 

Bans on abortion can mean a death sentence — for women with high-risk pregnancies whose doctors deny them life-saving medical care; for women resorting to unsafe methods out of fear of prosecution or due to a lack of alternatives; and for women in abusive relationships living in a country where homicide is the leading cause of death for pregnant women. 

This devastating decision comes right after the Court’s irresponsible ruling striking down a century-old New York law that limited the carrying of concealed firearms outside the home. This, despite the evidence that access to a gun makes it five times more likely that an abuser will kill their victim. 

As one of New York’s leading service providers for survivors of gender violence, we know how detrimental both rulings are to the safety and wellbeing of our clients and victims across the country. 

Today’s ruling grants more power to abusers who use sexual violence and reproductive coercion to control their victims. It also adds yet another barrier for survivors to whom abortion represents a lifeline and a path towards freedom from abuse. The Court’s ruling and the impending state bans will disproportionately affect women of color, trans and nonbinary people, women with disabilities, and those living in poverty who lack the resources to travel to states where abortion is legal. 

As horrifying as they are, these attacks on our rights will not deter us from our mission to build a world free from violence. Sanctuary stands more committed than ever to the Movement for Reproductive Justice and will prioritize access to abortion and gun control in our advocacy efforts.”


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Standing With LGBTQ+ Survivors

Intimate partner violence, like other forms of abuse­, does not discriminate based on sex, sexual orientation, gender identity, or expression.

Intimate partner violence, like other forms of abuse­, does not discriminate based on sex, sexual orientation, gender identity, or expression.

We also want to remind our fellow New Yorkers that Sanctuary’s services are free and available to ALL individuals regardless of race, color, sex, age, sexual orientation, gender identity and expression, religion, national origin, citizenship status, or marital status. If you or someone you know is experiencing abuse, please do not hesitate to reach out to us for help.

Keep reading to learn more about safety planning and download our guide by clicking here.

Sanctuary at NYC Pride 2019

Intimate Partner Violence in the LGBTQ+ Community

Abuse occurs in LGBTQ+ relationships at similar or even higher rates than in the general population. According to a 2010 CDC survey, the lifetime prevalence of intimate partner violence (IPV) is significantly higher for bisexual women (61%) compared to that of lesbian (43%) and heterosexual women (35%).[1] Lesbian women and gay men also reported experiencing levels of sexual and intimate partner abuse similar to or higher than those of their straight counterparts.

Although data on IPV in the transgender community is much more limited, studies suggest that 31 to 50 percent of transgender people suffer from intimate partner abuse at some point in their lives, compared to 28 to 33 percent in the general population.[2] One study found the prevalence of IPV experienced by trans women in the past year to be twice as high as that of trans men (16% vs. 8%), a finding consistent with the higher prevalence of intimate partner abuse among women in general.[3]

While it is often assumed that abusers are either the male or more masculine-presenting partner in a relationship, it is important to note that violence can be perpetrated by any individual regardless of their physical or personal attributes.[4]In the CDC study, for example, bisexual and heterosexual survivors, of various genders, overwhelmingly reported having only perpetrators of a different gender.

At Sanctuary for Families, we recognize that LGBTQ+ individuals’ experiences of abuse are too often ignored or dismissed. We also know that members of this community face unique barriers to seeking help because of their sexual orientation and/or gender identity and expression. These may include the risk of rejection and isolation from family and friends; fear of being outed by their partner in retaliation; misconceptions about abuse in same-sex relationships; homelessness and trauma from police brutality; lack of confidence in service providers due to potential homophobia; limited availability of or awareness about LGBTQ-specific or LGBTQ-friendly services; among others. Trans people, in particular, have been impacted by COVID-19, including increased unemployment and homelessness, while also struggling to find adequate medical care and support.

Every day, we at Sanctuary strive to create a welcoming environment that fosters compassion and mutual respect where all survivors can find safety and stability as they rebuild their lives in the aftermath of abuse. If you or someone you know is experiencing abuse, please do not hesitate to reach out.


Safety Planning: A Guide for Survivors, by Survivors

English | Español | Français | Deutschالعربية | 中文 | 한국어 

The following Safety Planning Guide was created by members of Sanctuary’s Survivor Leadership program and has been reviewed by multiple clinicians. The guide draws from survivors’ and clinicians’ expertise, as well as from safety planning models from the National Domestic Violence Hotline, Sanctuary for Families, and Love is Respect.


Download this guide with safety tips from survivors.

What Is a Safety Plan?

A safety plan is a set of steps you can take to reduce the risk of harm in unsafe situations with an abuser or family member. With the changes in our environments due to coronavirus, we advise survivors of gender-based violence to consider the following safety tips created by survivors.  Sanctuary for Families’ team of Survivor Leaders put this list together in hopes of providing digital tools for safety during this time.

Why Should I Create a Safety Plan?

It can be hard to think and react in a time of emergency or high stress, especially with the added stress and uncertainty of coronavirus, so it is helpful to create a plan in advance. It is also important to update your safety plan often, as circumstances can change.  Abusers often try to have power and control over a survivor’s life, and a safety plan is one way a survivor can have power and control over their own situation, as much as they can.  Having a plan can empower you to make the safest decisions you can for your situation.

You are the Expert

You know your situation better than anyone, so please individualize your safety plan to what feels safest for you.  If something does not feel safe, trust your instincts.  For example, it may not be safe to complete a safety plan in writing, but you can still review one in your head and memorize it as best you can.  It can also be helpful to go over your safety plan with a trusted friend or relative.

Digital Safety

Please try to use a safer computer or phone that someone abusive does not have direct or remote (hacking) access to.  Digital stalking is one way for abusers to try to exert power and control. Email and Instant/Text Messaging (IM) are not safe or confidential ways to talk to someone about the danger or abuse in your life. If possible, please call instead. If you use email or texting, please use a safer computer or phone and an account your abuser does not know about.

For more information on computers, the internet, and digital safety, click here.

Increased risk of harm due to COVID-19

As many of us are practicing social distancing and quarantine, there are many additional risks for survivors and their safety, such as:

  • Isolation: Abusers can use this time to further isolate survivors from their loved ones. They may also use this as a time to further restrict a survivor’s movement in person, controlling where they go and when. They might also control a survivor’s interactions online, limiting their access to the outside world.
  • Restricting Access to Information: Abusers may also restrict access to the news and other outlets, making themselves the source of all information.
  • Increased Abuse: The abuse may worsen during this time as survivors may be spending more time in contact with their abusers. Survivors may also experience new or different types of abuse during this time.
  • In-Person and Digital Stalking: Abusers might try to exert their power by trying to monitor, control and stalk survivors in person and digitally.
  • Financial Abuse: Many individuals are experiencing financial burdens due to being unable to work, and abusers may further financially exploit survivors during this time.
  • Parenting: Survivors who co-parent their children with their abusers may be facing unique challenges during these times, such as barriers to visitation and/or increased exposure to the abuser due to lack of accessible childcare.  For example, in order for a survivor to work, he/she/they may need to utilize their abuser for childcare.


1. Buddy System Code Word

Identify at least two people that you can contact with a “code word” to let them know if you are in trouble. Plan in advance what they should do if you send them the code word.

2. “Safest Room”

If there is an argument, identify an area of the home you can move to where there are no weapons and there are ways for you to leave the house, apartment, or building, such as a door or window to exit the house/apartment. For some survivors, especially those quarantined at home with an abuser during coronavirus, no room may feel safe, so we call it the “safest rooms”. If you can at least identify the lowest risk areas, you may be able to reduce harm.

3. Planning with Children

  • Code Words: If you have children, decide how to communicate urgency. For example, when one survivor’s daughter was little, the survivor would open her arms and the daughter knew that meant to come running to her for safety.  Some survivors also create a “code word” with their children that means they should go to the “safest room” in the home that you have already decided upon.
  • Emergency Numbers: If for some reason you are not able to make emergency calls and you have children, give them the safety number/s, if they are old enough. Please see the Resources section listed below for some emergency phone numbers.

4. Notifying the Police Before an Emergency

Ahead of time, you can notify your local police station of your concerns. Let them know the history and your concern of being in isolation due to coronavirus. It may be useful to speak with the Domestic Violence officer.

5. Exit Plan

In case you have to flee, create an exit plan ahead of time with someone who could support this need. Is there a trusted friend/relative who you can stay with if needed?

6. Supplies, Food & Medication

Check your supplies and food. If you need food and do not have the money, check your local pantry, temple/church/mosque/etc., or other community organizations. Remember to keep your medication in the safest, easily accessible location in case of emergency.

7. Emergency Bag

Pack an emergency bag with an extra set of keys, clothes for you and your children, a pay-as-you-go cell phone, medications, copies of important documents, etc.

8. Important Documents

Make copies or take pictures of your important documents for yourself and send them to a trusted friend or relative. Important documents may include IDs, social security cards, immigration documents, birth certificates, health insurance information, and Orders of Protection.  As mentioned earlier, be mindful of sending anything via phone or computer.  Please use whatever method is safest for you.

9. Seeking Social Support

With social distancing and quarantining, survivors can feel even more isolated, and abusers may use further isolation as a power and control tactic. Identify trusted friends, relatives or even online support groups where you can still connect virtually.  If you have a friend who may be experiencing abuse, be sure to reach out to them even more during this time.

10. Creating a “Peaceful Space”

Many survivors are feeling forced to spend more time with an abuser during the coronavirus outbreak because they may feel unsafe leaving the home, as well as unsafe staying in the home. If you cannot leave your home, try to create a “peaceful space” for yourself in your home (if that is safe for you). You can draw pictures of a more peaceful place and put them on a wall to help you take an emotional break to visualize a more peaceful place.  This is also an activity you can do with your children.  You can also write positive affirmations and put them up on the wall to remind yourself of your worth.

11. Holding onto Your Plan

Consider keeping a list of your safety plan in your phone or wherever might be safe for you. Please consider what is safest for you. If you choose to write your plan somewhere, consider listing only key words that help you remember the plan, but that would not be clear to your abuser. If this is not safe, try to memorize your plan, focusing on memorizing at least one key emergency number on your list of resources.


All of the following resources are accessible, despite the coronavirus outbreak.

  • 9-1-1: In case of an emergency at any time, please call 911.
  • Emergency SOS on iPhone: Here is a link to a shortcut to using Emergency SOS to quickly and easily call for help and alert your emergency contacts if you have an iPhone: How to Use Emergency SOS on your iPhone
  • Emergency Location Sharing on Androids and iPhones: Here is a link for how to set up emergency location sharing on your phone, in case you want to share your location with a trusted friend or relative in case of emergency: How to Use Emergency Location Sharing
  • Sanctuary for Families Hotline: Sanctuary for Families’ Hotline is still accessible from Monday-Friday from 9 AM- 5 PM. Please call us at 212-349-6009
  • National Domestic Violence Hotline: The National Domestic Violence Hotline is still accessible 24/7. Please call them at 1-800-799-7233
  • National Human Trafficking Hotline: The National Human Trafficking Hotline is still accessible 24/7. Please call them at 1-888-373-7888 or text them at 233-733
  • Suicide Hotline: The National Suicide Prevention Lifeline is still accessible 24/7. Please call them at 1-800-273-8255

By: Monica Harris, Survivor Leader & Shobana Powell, LCSW, Director of Survivor Leadership Institute.

Reviewed by: Flore Baptiste, Carmen Guzman Lombert, Survivor Leader, Cristian Eduardo, Survivor Leader, and Hazell Imbert, LMHC, Counselor in Residential Services.

[1] Walters, M.L, J. Chen, and M.J. Breiding. “The National Intimate Partner and Sexual Violence Survey (NISVS): 2010 Findings on Victimization by Sexual Orientation.” Atlanta, GA: National Center for Injury Prevention and Control, Centers for Disease Control and Prevention, 2013.

[2] Brown, Taylor N.T., and Jody L. Herman. “Intimate Partner Violence and Sexual Abuse among LGBT People.” Los Angeles, CA: The Williams Institute, UCLA School of Law, 2015.

[3] Clements, K., M. Katz, and R. Marx. “The Transgender Community Health Project.” San Francisco, CA: University of California San Francisco, 1999.

[4] Human Rights Campaign. “Common Myths about LGBTQ Domestic Violence,” October 18, 2017.

FAQs: New York City Renters’ Rights during COVID-19

Know your rights and learn what the Supreme Court’s latest eviction ruling means for NYC.

Last Updated 09/02/21

On Thursday, August 26, the US Supreme Court struck down a federal eviction freeze designed to keep tenants housed in New York City and other places with high rates of COVID-19. But on September 1st, Gov. Hochul signed a law amending and extending New York’s eviction protections through January 15, 2022. 

See below for answers to frequently asked questions about NYC renters’ rights during COVID-19:

I submitted a Hardship Declaration and/or a CDC Declaration to my landlord or the court, what protections do I have?

Can I be physically removed from my home?

I have fallen behind on my rent. What do I do?

My landlord is threatening to evict me. What can I do?

1. I submitted a Hardship Declaration and/or a CDC Declaration to my landlord or the court, what protections do I have?

    • On September 1, 2021, Gov. Hochul signed a law, providing that if you previously submitted a Hardship Declaration (see below) to your landlord or the court, no steps may be taken to evict you until at least January 15, 2022 (subject to the exceptions outlined below)
    • On August 26, 2021, the Supreme Court issued an order vacating the CDC’s nationwide moratorium on evictions of any tenants who submit a CDC Declaration.
      • This means CDC Declarations no longer protect tenants from evictions.
      • If you submitted a CDC Declaration only, you should submit a Hardship Declaration to your landlord and/or the court as soon as possible.

2. Can I be physically removed from my home?

Was a judgment of possession and warrant of eviction issued against you and/or were you served with a Notice Eviction?

  • If YES, before you can be removed, your landlord must file a motion, asking the court for permission to move forward with the eviction, AND the court must hold a status conference.
    • If you provide a Hardship Declaration (see below) to your landlord or the court, you cannot be removed until at least January 15, 2022 (subject to the exceptions outlined below)
  • If NO, see the section below addressing New & Pending Cases

New & Pending Eviction Cases

Were you served with a Notice of Petition and Petition, indicating that your landlord has commenced an eviction case against you in NYC Housing Court?

    • If YES, if you provide a Hardship Declaration (see below) to your landlord or the court, the case is stayed until at least January 15, 2022 (subject to the exceptions outlined below)
      • Email your Hardship Declaration to the housing court for your borough:
    • If NO, if you provide a Hardship Declaration (see below) to your landlord, your landlord cannot commence an eviction case against you until at least January 15, 2022 (subject to the exceptions outlined below)

    • In addition, if you apply for rental assistance from ERAP (see below), your landlord cannot commence or move forward with an eviction case against you, until you receive a decision regarding your eligibility for ERAP.
      • If you applied for ERAP but also owe rent from before March 14, 2020, the judge may allow the case to move forward, unless you submit a Hardship Declaration.

Default Judgement

Normally, if you fail to timely “Answer” a Notice of Petition and Petition, your landlord can obtain a “default judgment” of possession and warrant of eviction against you, and proceed with removing you from your home.

    • As of September 1, 2021, your landlord cannot obtain a default judgment against you until at least January 15, 2022, unless the landlord first files a motion, and the court holds a hearing
      • If you provide a Hardship Declaration (see below) to your landlord or the court, the case is stayed until at least January 15, 2022 (subject to the exceptions outlined below)
    • If a default judgment was issued against you prior to December 28, 2020, or between August 13, 2021 and September 1, 2021:
      • The judge must remove the default judgment upon your request; and
      • If you provide a Hardship Declaration (see below) to your landlord or the court, the case is stayed until at least January 15, 2022 (subject to the exceptions outlined below)

Hardship Declaration

You cannot be evicted until at least January 15, 2022, if you provide your landlord or the court with a declaration, indicating that you qualify for eviction protection because:

    • You are experiencing financial hardship, unable to pay your rent in full, or unable to obtain alternative suitable permanent housing because of: 
      • Significant loss of household income during COVID-19 pandemic;
      • Increase in necessary out-of-pocket expenses related to performing essential work or health impacts during COVID-19 pandemic; 
      • Inability to obtain meaningful employment or earn income, or increase in necessary out-of-pocket expenses, due to childcare responsibilities or responsibilities to care for an elderly, disabled, or sick family member during COVID-19 pandemic; 
      • Hardship to relocate during COVID-19 pandemic, due to moving expenses and difficulty securing alternative housing; or 
      • Inability to obtain meaningful employment or earn income, or significant reduction in income or increase in expenses, due to other circumstances related to COVID-19 pandemic; and / or
    • Vacating and moving into new permanent housing would pose a significant health risk because you or household member have an increased risk for severe illness or death from COVID-19 due to being over age of 65, having a disability, or having an underlying medical condition

Exceptions: Evictions protections by submitting Hardship Declaration do not apply if:

    • Petition filed against you alleges nuisance: “unreasonable behavior that substantially infringes on the use and enjoyment of other tenants or occupants or causes substantial safety hazard to others.”
    • Petition filed against you alleges that you intentionally caused significant damage to the property
    • Your landlord files a motion, alleging that you have not experienced hardship and, after a hearing, the court determines that your hardship claim is invalid 

Visit this website to download the Hardship Declaration in several languages:

3. I have fallen behind on my rent. What do I do?

    • To date, no law has been passed that would absolve you of your obligation to pay rent; accordingly, you are still legally required to pay all rent owed to your landlord.
    • However, the Tenant Safe Harbor Act provides that you cannot be evicted (via a judgment of possession and warrant of eviction) for nonpayment of rent for the “COVID-19 covered period” beginning March 7, 2020 and ending June 24, 2021, if you have suffered financial hardship during such period.
      • However, your landlord can still get a money judgment against you for unpaid rent during the COVID-19 covered period.
      • Further, if you fell behind on rent, or a judgment of possession and warrant of eviction were issued against you, prior to March 7, 2020, or you have fallen behind on rent after June 24, 2021, you are still vulnerable to eviction, subject to the protections described above.
    • New York has established ERAP to distribute over $2.7 billion of federal funds, and cover up to one year of rental arrears, beginning on March 13, 2020, and up to three months of rent after you apply.
      • To qualify, renters must demonstrate: household income at or below 80% AMI (in 2020 OR at time of application); experiencing financial hardship due to COVID-19 (e.g. qualified for unemployment, experienced reduction in household income; incurred significant costs); risk of homelessness.
      • The program will prioritize, among other things, households below 50% AMI; households with individuals who have been unemployed for 90 days prior to application; victims of domestic violence; eviction case pending
        • Households living in state or federally-subsidized housing (e.g. NYCHA, Section 8, FHEPS, CityFHEPS) will be last priority.
      • Undocumented New Yorkers may qualify, and documentation of immigration status will not be required as part of the application process.
      • No eviction proceeding may be commenced against an applicant for this program, and any pending eviction proceedings shall be stayed pending determination of application.

If you cannot pay all of the rent owed, you can: 

    • Talk to your landlord, and try to negotiate a payment plan.
    • Before you apply for a one-shot deal from HRA, you must first apply for ERAP

4. My landlord is threatening to evict me. What can I do?

    • If your landlord illegally locks you out, call 911 to be restored to your apartment.
    • Report harassment or discrimination by contacting 311.