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 ...
THIRD CAUSE OF ACTION (Other Wrongful Conduct in Violation of Section 1 of the Sherman Act) 97. Plaintiffs repeat and reallege the allegations of Paragraphs 1 through 85 as if set forth fully herein. 98. Defendants possess significant market power. Collectively, Defendants are reported to be the ...
72.instead of honoring those obligations to Plaintiffs, Defendant's conduct and admissions show that they do not even consider Plaintiffs to be their clients. If Defendants truly were managers of the models, then they would refer to the models as their clients. If Defendants are employment ...
FOURTH CAUSE OF ACTION ~ (Violations of GBL 170 -190) 104. Plaintiffs repeat and reallege the allegations of Paragraphs 1 through 85 as if set forth fully herein. 105. GBL 186 provides in relevant part, "Any employment agency which collects, receives or retains a fee or other placement ...