FIRST CAUSE OF ACTION (price-Fixing as Per Se Violation of Section 1 of the Sherman Act) 85. Plaintiffs repeat and reallege the allegations of Paragraphs 1 through 85 as if set forth fully herein. 6. For least the last several years, Defendants have been engaged in an unlawful conspiracy to fix the ...
SECOND CAUSE OF ACTION (Conspiracy to Evade State Price Regulation as Per Se Violation of Section 1 of the Sherman Act) 92. Plaintiffs repeat and reallege the allegations of Paragraphs 1 through 85 as if set forth fully herein. 93. For least the last several years, Defendants have been engaged in ...
Parties 5. Plaintiff Amanda Masters is a resident of Los Angeles, California. Ms. Masters worked as a model with Defendants, Wilhelmina Model Agency, Inc., Next Management Corp., Zoli Management Inc., and Click Model Management, Inc. During the class period. 6. Plaintiff Justin Kenner is a resident ...
Defendants' Unlawful Price Fixing Scheme 48. Defendants' scheme to evade state law limiting their fees, and their agreement on what fees to charge, is also a clear violation of federal antitrust law. 49. As noted, evidence of the inception of this unlawful scheme comes from the sworn statement of ...
Defendants' Illegal Exchanges of Information to Facilitate their Price-Fixing: Conspiracy 52. Defendants have maintained their collusive price structure through the years in various ways, including formal and informal meetings at which they have exchanged information on rates, charges, and other ...
Defendants' Concerted Efforts to Evade Regulation as Employment Agencies 42. GBL 170 - 190 were consistently understood to apply to "modeling agencies" such as Defendants until the 1970's, when - according to court papers filed by counsel for Defendant Elite (then a newcomer challenging ...