IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

JANE DOE 1, : 

 Individually and on behalf of 

 all others similarly situated, : 

 Case No. 2:18-cv-443 

AND : 

 Judge: 

JANE DOE2, : 

 Individually and on behalf of Magistrate Judge: 

 all others similarly situated, : 

 

AND : 

 

JANE DOE 3 : 

 Individually and on behalf of 

 all others similarly situated : 

 Plaintiffs, : 

v. : 

VM3015, INC., : 

 

 d/b/a The Doll House of Columbus : 

 1680 Karl Court 

 Columbus, Ohio 43229 : CLASS ACTION COMPLAINT 

 JURY DEMAND ENDORSED 

 : HEREON 

 Serve Also Its Registered Agent 

 Keith E. Golden : 

 923 E. Broad Street 

 Columbus, Ohio 43205 : 

 

AND : 

 

HOUSE OF BABES : 

2595 South High Street 

Columbus, Ohio 43207 : 

AND : 

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LL ENTERTAINMENT, LLC, : 

 d/b/a Private Dancer Club : 

 3609 Trabue Road 

 Columbus, Ohio 43228 : 

 Serve Also Its Registered Agent : 

 C. William Klausman 

 75 E. Gay Street, Suite 300 : 

 Columbus, Ohio 43215 

 : 

AND 

 : 

X GENTLEMEN’S CLUB 

 6223 Sunderland Drive : 

 Columbus, Ohio 43229 

 : 

AND 

 : 

CHEEKS GENTLEMEN’S CLUB 

 906 Water Tower Lane : 

 West Carrollton, Ohio 45449 

 : 

AND 

 : 

CLUB ROG 

 2460 W. McPherson Way : 

 Fremont, Ohio 43420 

 : 

AND 

 : 

NL CORP., INC., : 

 d/b/a Diamonds Cabaret : 

 960 Miamisburg Centerville Road 

 Washington Township, Ohio 45459 : 

Serve Also Its Registered Agent : 

 Michael Boutros 

 5785 Far Hills Avenue : 

 Dayton, Ohio 45429 

 : 

AND 

 

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SCARLETT’S CABARET TOLEDO : 

 5765 Telegraph Road 

 Toledo, Ohio 43612 : 

AND : 

PSG FOODS, LLC, : 

 d/b/a Platinum Showgirls : 

 5801 Telegraph Road 

 Toledo, Ohio 43612 : 

 Serve Also Its Registered Agent : 

 C. William Klausman 

 75 E. Gay Street, Suite 300 : 

 Columbus, Ohio 43215 

 : 

AND 

 : 

HSG FOODS, LLC, 

 : 

 d/b/a Hush Showgirls 

 532 S. Reynolds Road : 

 Toledo, Ohio 43615 

 : 

 Serve Also Its Registered Agent 

 Naqid Hasan : 

 532 S. Reynolds Road 

 Toledo, Ohio 43615 : 

 

AND : 

TOP HAT GENTLEMEN’S CLUB : 

 1901 Ashland Road 

 Mansfield, Ohio 44905 : 

AND : 

COUNTRY TIME : 

 1006 County Highway 330 

 Nevada, Ohio 44849 : 

AND : 

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SHARKEY’S LOUNGE : 

6028 N. Dixie Drive 

Dayton, Ohio 45414 : 

AND : 

PINUPS AND PINTS : 

10963 Lower Valley Pike 

Medway, Ohio 45341 : 

AND : 

PAZZAZZ SHOW CLUB : 

 8911 Kingsridge Drive 

 Dayton, Ohio 45458 : 

AND : 

SHOWTIME GENTLEMEN’S CLUB : 

 2921 Crider Road 

 Mansfield, Ohio 44907 : 

AND : 

NEW YORK-NEW YORK CABARET : 

 1221 E. 2nd Street 

 Franklin, Ohio 45005 : 

AND : 

THE LIVING ROOM : 

 3830 N. Dixie Drive 

 Dayton, Ohio 45414 : 

 

AND : 

BOTTOMS UP LOUNGE : 

 567 Grant Street 

 Akron, Ohio 44311 : 

AND : 

JEN’S DEN : 

 1335 Brittain Road 

 Akron, Ohio 44310 : 

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AND : 

CRAZY HORSE MEN’S CLUB : 

 25540 Miles Road 

 Bedford, Ohio 44146 : 

AND : 

CRAZY HORSE : 

 1438 St. Clair Avenue 

 Cleveland, Ohio 44114 : 

AND : 

SECRETS GENTLEMEN’S CLUB : 

 12820 Brookpark Road 

 Cleveland, Ohio 44130 : 

AND : 

AMBER’S CABARET : 

 13311 Brookpark Road 

 Brook Park, Ohio 44142 : 

AND : 

THE BUCKEYE ASSOCIATION OF CLUB : 

EXECUTIVES, INC., 

 : 

 d/b/a BACE Ohio 

 4915 North Dixie Drive : 

 Dayton, Ohio 45414 

 : 

 Serve Also Its Registered Agent 

 Carolyn A. Prater : 

 2232 Coronette Avenue 

 Dayton, Ohio 45414 : 

AND : 

 

JOHN DOE BACE MEMBER : 

GENTLEMEN’S CLUBS 1-20 

 : 

 Defendants. 

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COLLECTIVE ACTION COMPLAINT FOR 

DECLARATORY JUDGMENT AND COMPENSATION 

UNDER 29 U.S.C. §§ 201, et. seq.

AND 

CLASS ACTION COMPLAINT 

UNDER OHIO REVISED CODE CHAPTER 4111, et seq.

Now come Plaintiffs, on behalf of themselves and all others similarly situated, and bring 

this collective and class action against DefendantsVM3015, Inc., doing business as The Doll 

House of Columbus (“Defendant Doll House”); House of Babes (“House of Babes Defendants”); 

Private Dancer (“Private Dancer Defendants”); X Gentlemen’s Club (“X Club 

Defendants”),Cheeks Gentlemen’s Club (“Cheeks Defendants”); Club Rog (“Club Rog 

Defendants”); Diamonds Cabaret (“Diamonds Defendants”); Scarlett’s of Toledo (“Scarlett’s 

Toledo Defendants”); Platinum Showgirls (“Platinum Showgirls Defendants”); Hush Showgirls 

(“Hush Defendants”); Top Hat Gentleman’s Club (“Top Hat Defendants”); Country Time 

(“Country Time Defendants”); Sharkey’s Lounge (“Sharkey Defendants”); Pinups and Pints 

(“Pinups and Pints Defendants”); Pazzazz Show Club (“Pazzazz Defendants”); Showtime 

Gentlemen’s Club (“Showtime Defendants”); New York-New York Cabaret (“NYNY Cabaret 

Defendants”); The Living Room (“Living Room Defendants”); Bottoms Up Lounge (“Bottoms 

Up Defendants”); Jen’s Den (“Jen’s Defendants”); Crazy Horse Men’s Club (“Crazy Horse 

Men’s Defendants”); Crazy Horse (“Crazy Horse Defendants”); Secrets Gentlemen’s Club 

(“Secrets Defendants”); Amber’s Cabaret (“Amber’s Defendants”); The Buckeye Association of 

Club Executives, Inc., doing business as BACE Ohio (“Defendant BACE Ohio”); and John Does 

1-20 (all Defendants referred to collectively as “Defendants”) for monetary, declaratory, and 

injunctive relief due to its willful failure to compensate employees with proper pay in violation 

of the federal Fair Labor Standards Act of 1938 (”FLSA”), 29 U.S.C. §§ 201, et seq., the Ohio 

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Minimum Fair Wage Standards Act (“OMFWSA”), O.R.C. §§ 4111.01, et seq., the Ohio SemiMonthly Payment Act O.R.C. § 4113.15,common law unjust enrichment, Section 1 of the 

Sherman Act 1 U.S.C. § 1, the Ohio Valentine Act R.C. § 1331.01, et seq., and Ohio common 

law civil conspiracy by intentionally failing to pay full and accurate wages to employees for each 

hour worked in accordance with federal and Ohio law. In support of the claims stated above, 

Plaintiffs allege the following: 

INTRODUCTION 

1. Plaintiffs follow in the footsteps of exotic dancers across the country that have 

stood up against gentlemen’s clubs and their owners for subjecting them to oppressive, illegal 

pay policies that fail to pay them any wages whatsoever. Plaintiffs were subject to a statewide 

industry conspiracy, perpetrated by gentlemen’s clubs throughout the State of Ohio. This case 

seeks to end these unlawful and collusive practices in Ohio and to restore to the affected dancers 

the amounts owed to them under Federal and Ohio State law. 

2. Defendants own and operate gentlemen’s clubs throughout the State of Ohio that 

were or are member clubs of the industry lobbying / trade organization Defendant BACE Ohio. 

Defendants have for years engaged in a statewide effort to conspire among themselves to 

illegally depress and deny minimum and overtime wages to dancers working at the clubs. In 

furtherance of their industry wide conspiracy, Defendants regularly exchanged—during trade 

organization member meetings—non-public information about the pay structure applied to 

Dancers and the compensation paid to Dancers. Additionally Defendants colluded and agreed to 

use similar documents that set forth the employee status of dancers. 

3. As a result of Defendants’ conspiracy and implementation of illegal pay schemes, 

no Defendant pays any wages whatsoever to any of its Dancer employees. Defendants’ actions 

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violate Section 1 of the Sherman Act 1 U.S.C. § 1, the Ohio Valentine Act R.C. § 1331.01, et 

seq., and Ohio common law civil conspiracy. Plaintiffs, on their own behalf, and on behalf of the 

Statewide Conspiracy Class of Dancers defined below, seek to recover for the wages unlawfully 

denied to them as a result of Defendants’ conspiracy to perpetuate an illegal pay system. 

4. Plaintiffs additionally bring hybrid collective action / class action wage and hour 

claims against the clubs at which they worked as Dancers i.e., the Wage and Hour Defendants. 

The Wage and Hour Defendants failed to pay employees at least minimum wage for all hours 

worked as required under Federal and Ohio laws. Plaintiffs therefore bring claims pursuant Fair 

Labor Standards Act, 29§§ 201, et seq., the Ohio Minimum Fair Wage Standards Act 

(“OMFWSA”), O.R.C. §§ 4111.01, et seq., the Ohio Semi-Monthly Payment Act O.R.C. § 

4113.15, and common law unjust enrichment against the Doll House Defendants, House of 

Babes Defendants, Private Dancer Defendants, and Club X Defendants (collectively “the Wage 

and Hour Defendants”) to redress long standing abuse of the federal minimum wage and 

overtime standards. 

5. Given the sensitive and intimate nature of such a lawsuit, and the significant fear 

of and potential for retaliation in this type of action, Plaintiffs Jane Does 1, 2, and 3 seek to 

proceed pseudonymously in public filings and keep their identity private. 

6. The privacy interest of Jane Does 1, 2 and 3 substantially outweighs the 

presumption of open judicial proceedings; specifically prosecution of the suit will allow 

Plaintiffs to disclose information of the utmost intimacy. The privacy interests of Jane Does 1, 2 

and 3 also substantially outweigh the customary practice of judicial openness because the 

inherent danger of disclosing their true identity in connection with their history of performing 

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adult entertainment may invite stigma from their family, friends, community, current employers, 

and/or prospective employers. 

7. The Wage and Hour Defendants frequently allow Dancers to use fictitious stage 

names because of the inherent risks to Dancers in the industry and for the privacy and physical 

well-being of the Dancers. If current/former patrons know their true identity they may seek to 

stalk, commit violence, and/or injure Jane Does 1, 2 and 3. 

JURISDICTION AND VENUE 

8. This Court has jurisdiction over Plaintiffs’ FLSA claims pursuant to 28 U.S.C. § 

1331, 28 U.S.C. § 1331, 28 U.S.C. § 1337(a), and 29 U.S.C. §216(b). 

9. This Court has jurisdiction over Plaintiffs’ federal antitrust claims, which seek to 

secure injunctive relief and damages for violation of the Sherman Act, 15 U.S.C. § 1, pursuant to 

28 U.S.C. §§ 1331 and 1337, and Sections 4 and 16 of the Clayton Act, 15 U.S.C. §§ 15(a) and 

26. 

10. This Court has supplemental jurisdiction over Plaintiffs’ OMFWSA claims 

pursuant to 28 U.S.C. § 1367 for those claims authorized under Ohio Revised Code Chapter 

4111.01, et seq.

11. This Court has supplemental jurisdiction over Plaintiffs’ state antitrust, and civil 

conspiracy claims pursuant to 28 U.S.C. § 1367. 

12. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) and S.D. Ohio 

Civ. R. 82.1(b) because the acts giving rise to the claims of the Plaintiffs occurred within this 

judicial district, and Defendants regularly conduct business in and have engaged and continue to 

engage in the wrongful conduct alleged herein and thus, are subject to personal jurisdiction 

within this judicial district. 

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13. Pursuant to Southern District of Ohio Local Rule 3.1(b) this case is related to 

Hogan v. Cleveland Ave. Restaurant, Inc., Case No. 2:15-cv-2883; De Angelis v. National 

Entertainment Group, LLC, Case No. 2:17-cv-924; De Angelis v. Nolan Enterprises, Inc., Case 

No. 2:17-cv-926; De Angelis v. Icon Entertainment Group, Inc., Case No. 2:17-cv-927; and De 

Angelis v. C G Consulting, et al., Case No. 2:17-cv-985 before Judge Algenon L. Marbley and 

Magistrate Elizabeth P. Deavers. Each case arises from the same type of event, calls for a 

determination of the same or substantially identical questions of law or fact, and would entail 

substantial duplication of effort and expense by the Court if heard by different judges. Each case 

is a wage and hour / conspiracy case for failure to pay wages according to federal and Ohio State 

law. Each case is brought against a gentlemen’s strip club defendant in Ohio by and on behalf of 

a putative class of Dancers. Each club maintained nearly identical illegal policies that deprived 

Dancers of the wages they were entitled to under the law. Accordingly, each case is clearly 

related and it would be unnecessarily duplicative to have the cases handled by multiple Judges. 

PARTIES 

14. Plaintiff Jane Doe 1 is a citizen of the State of Ohio employed by Doll House 

Defendants as a Dancer in Columbus, Ohio during the statutory period covered by this 

Complaint—she did not receive the FLSA-mandated minimum wage for all hours worked nor 

did she receive time and a half her regular rate of pay for hours worked over forty in a given 

workweek. . 

15. Plaintiff Jane Doe 2 is a citizen of the State of Ohio employed by Doll House 

Defendants, Club X Defendants, and Private Dancer Defendants as a Dancer in Columbus, Ohio 

during the statutory period covered by this Complaint—she did not receive the FLSA-mandated 

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minimum wage for all hours worked nor did she receive time and a half her regular rate of pay 

for hours worked over forty in a given workweek. 

16. Plaintiff Jane Doe 3 is a citizen of the State of Ohio employed by House of Babes 

Defendants as a Dancer in Columbus, Ohio during the statutory period covered by this 

Complaint—she did not receive the FLSA-mandated minimum wage for all hours worked nor 

did she receive time and a half her regular rate of pay for hours worked over forty in a given 

workweek. 

17. Defendant VM3015, Inc., doing business as The Doll House of Columbus (“Doll 

House Defendants”) is a for profit corporation registered to do business in Ohio and a member of 

The Buckeye Association of Club Executives. Defendant’s principal place of business is 1680 

Karl Court, Columbus, Ohio 43229. 

18. Defendant House of Babes (“House of Babes Defendants”) is a gentleman’s club 

doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 2595 South High Street, Columbus, Ohio 43207. 

19. Defendant LL Entertainment, LLC, doing business as Private Dancer Club 

(“Private Dancer Defendants”) is a domestic limited liability company registered to do business 

in Ohio and a member of The Buckeye Association of Club Executives. Defendant’s principal 

place of business is 3609 Trabue Road, Columbus, Ohio 43228. 

20. Defendant X Gentleman’s Club (“X Club Defendants”) is a gentleman’s club 

doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 6223 Sunderland Drive, Columbus, Ohio 43229. 

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21. Defendant Cheeks Gentleman’s Club (“Cheeks Defendants”) is a gentleman’s 

club doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 906 Water Tower Lane, West Carrollton, Ohio 45449. 

22. Defendant Club Rog (“Club Rog Defendants”) is a gentleman’s club doing 

business in Ohio and a member of The Buckeye Association of Club Executives. Defendant’s 

principal place of business is 2460 W. McPherson Way, Freemont, Ohio 43420. 

23. Defendant NL Corp., Inc., doing business as Diamonds Cabaret (“Diamonds 

Defendants”) is a for profit corporation registered to do business in Ohio and a member of The 

Buckeye Association of Club Executives. Defendant’s principal place of business is 960 

Miamisburg Centerville Road, Washington Township, Ohio 45459. 

24. Defendant Scarlett’s Cabaret Toledo (“Scarlett’s Toledo Defendants”) is a 

gentleman’s club doing business in Ohio and a member of The Buckeye Association of Club 

Executives. Defendant’s principal place of business is 5765 Telegraph Road, Toledo, Ohio 

43612. 

25. Defendant PSG Foods, LLC, doing business as Platinum Showgirls (“Platinum 

Showgirls Defendants”) is a domestic limited liability company registered to do business in Ohio 

and a member of The Buckeye Association of Club Executives. Defendant’s principal place of 

business is 5801 Telegraph Road, Toledo, Ohio 43612. 

26. Defendant HSG Foods, LLC, doing business as Hush Showgirls (“Hush 

Defendants”) is a domestic limited liability company registered to do business in Ohio and a 

member of The Buckeye Association of Club Executives. Defendant’s principal place of 

business is 532 S. Reynolds Road, Toledo, Ohio 43615. 

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27. Defendant Top Hat Gentlemen’s Club (“Top Hat Defendants”) is a gentleman’s 

club doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 1901 Ashland Road, Mansfield, Ohio 44905. 

28. Defendant Country Time (“Country Time Defendants”) is a gentleman’s club 

doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 1006 County Highway 330, Nevada, Ohio 44849. 

29. Defendant Sharkey’s Lounge (“Sharkey’s Defendants”) is a gentleman’s club 

doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 6028 N. Dixie Drive, Dayton, Ohio 45414. 

30. Defendant Pinups and Pints (“Pinups and Pints Defendants”) is a gentleman’s 

club doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 10963 Lower Valley Pike, Medway, Ohio 45341. 

31. Defendant Pazzazz Show Club (“Pazzazz Defendants”) is a gentleman’s club 

doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 8911 Kingsridge Drive, Dayton, Ohio 45458. 

32. Defendant Showtime Gentlemen’s Club (“Showtime Defendants”) is a 

gentleman’s club doing business in Ohio and a member of The Buckeye Association of Club 

Executives. Defendant’s principal place of business is 2921 Crider Road, Mansfield, Ohio 

44907. 

33. Defendant New York-New York Cabaret (“NYNY Cabaret Defendants”) is a 

gentleman’s club doing business in Ohio and a member of The Buckeye Association of Club 

Executives. Defendant’s principal place of business is 1221 E. 2nd Street, Franklin, Ohio 45005. 

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34. Defendant The Living Room (“Living Room Defendants”) is a gentleman’s club 

doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 3830 N. Dixie Drive, Dayton, Ohio 45414. 

35. Defendant Bottoms Up Lounge (“Bottoms Up Defendants”) is a gentleman’s club 

doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 567 Grant Street, Akron, Ohio 44311. 

36. Defendant Jen’s Den (“Jen’s Defendants”) is a gentleman’s club doing business in 

Ohio and a member of The Buckeye Association of Club Executives. Defendant’s principal place 

of business is 1335 Brittain Road, Akron, Ohio 44310. 

37. Defendant Crazy Horse Men’s Club (“Crazy Horse Men’s Defendants”) is a 

gentleman’s club doing business in Ohio and a member of The Buckeye Association of Club 

Executives. Defendant’s principal place of business is 25540 Miles Road, Bedford, Ohio 44146. 

38. Defendant Crazy Horse (“Crazy Horse Defendants”) is a gentleman’s club doing 

business in Ohio and a member of The Buckeye Association of Club Executives. Defendant’s 

principal place of business is 1438 St. Clair Avenue, Cleveland, Ohio 44114. 

39. Defendant Secrets Gentleman’s Club (“Secrets Defendants”) is a gentleman’s 

club doing business in Ohio and a member of The Buckeye Association of Club Executives. 

Defendant’s principal place of business is 12820 Brookpark Road, Cleveland, Ohio 44130. 

40. Defendant Amber’s Cabaret (“Amber’s Defendants”) is a gentleman’s club doing 

business in Ohio and a member of The Buckeye Association of Club Executives. Defendant’s 

principal place of business is 13311 Brookpark Road, Brook Park, Ohio 44142. 

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41. Defendant The Buckeye Association of Club Executives, Inc., doing business as 

BACE Ohio is a non-profit corporation registered in the State of Ohio. Defendant’s principal 

place of business is 4915 North Dixie Drive, Dayton, Ohio 45414. 

42. John Does 1-20 are not yet known gentlemen’s clubs that acted as coconspirators 

with the named Defendants. John Does 1-20 will be named and served as soon as their identities 

become known to Plaintiffs. 

43. On information and belief, at all times relevant to this lawsuit, Defendants have 

gross operating revenues or business volume in excess of $500,000. 

44. The putative Wage and Hour Class Action Members are all current and former 

Dancers who work or worked for the Wage and Hour Defendants at any time within the six years 

prior to the date of the filing of this Complaint through the date of the final disposition of this 

action. 

45. The putative Wage and Hour Collective Action Members are all current and 

former Dancers who worked for the Wage and Hour Defendants at any location at any time 

within the three years prior to the filing of this Complaint through the date of final disposition of 

this action who did not receive minimum wages or overtime premium pay for hours worked over 

forty in a given workweek. 

46. The putative Statewide Conspiracy Class Action Members are all current and 

former Dancers who work or worked for the statewide Defendants at any time within the six 

years prior to the date of the filing of this Complaint through the date of the final disposition of 

this action. 

47. Plaintiffs’ consents to participate in this lawsuit are attached as Exhibit A to this 

complaint. 

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FACTUAL ALLEGATIONS 

48. The Defendants consist of an industry lobbying / trade organization (BACE 

Ohio), and the gentlemen’s club members of the organizations. The Defendants engaged in a 

conspiracy to employ an industry wide illegal pay system across Ohio whereby clubs deny 

Dancers their rightful minimum and overtime wages, and require Dancers to pay various 

collusive, artificial, and illegal fees to club owners including a fee called “rent.” By these 

unlawful and collusive practices, clubs throughout Ohio pay their dancers no wages. 

49. This illegal system is referred to as the “Tenant System.” Under this system 

Defendants actually exact money from the dancers for the privilege of working at their club. 

50. Defendants, upon information and belief, created and propagated the Tenant 

System through the industry lobbying / trade organization BACE Ohio. Defendants used BACE 

Ohio as to tool to collude, conspire, and engage in anticompetitive activities. 

51. Defendants agreed to and did classify their Dancer employees as independent 

contractors. 

52. Each coconspirator is jointly and severally liable for the wage fixing and damages 

every Dancer suffered at every club. 

53. Plaintiffs worked as Dancers in multiple Ohio gentlemen’s clubs. Upon 

information and belief, this is common practice for exotic dancers, and Dancers are class of 

individuals that work often times work at multiple different gentlemen’s clubs. Plaintiffs worked 

at other clubs that are not named in this lawsuit. 

54. Defendant Doll House employed Plaintiff, Jane Doe 1, from about February 2015 

to January 2017. 

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55. Defendants Doll House, Club X, and Private Dancer employed Plaintiff, Jane Doe 

2, from about April 2016 to February 2017. 

56. Defendant House of Babes employed Plaintiff, Jane Doe 3, from about January 

2016 to March 2016. 

57. During all relevant times, Defendants were employers within the meaning of the 

FLSA and the OMFWSA. 

58. Defendants maintained substantial control over Plaintiffs and Dancers. 

59. Plaintiffs received money exclusively from customers at the club. 

60. Defendants scheduled Dancers on specific days throughout the workweek. 

61. Plaintiffs and Dancers were expected, to and typically worked at least a full forty 

hour workweek and sometimes more. 

62. Defendants penalized Dancers for being late or missing work and were required to 

pay a fine before they were allowed to work again. 

63. Defendants required Plaintiffs and Dancers to sign in with a manager or DJ (or 

other employee if neither was available) before getting dressed for the night. 

64. Defendants maintained specific rules that all Dancers had to follow. These rules 

included a dress code and Dancer etiquette. 

65. Defendants set the price that Dancers could charge for drinks, table dances, 

private dances, and all other services. Dancers could not set their own prices for any services. 

66. Defendants had absolute control over admitting patrons and set the door price for 

admission. Dancers had no say in this matter. 

67. Defendants handled all advertising and promotional activity, and determined what 

services Dancers would offer. Dancers had no say in this matter. 

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68. At the end of every night, Defendant took a cut from all money customers gave 

dancers. This included fees and money earned from dances and drinks. 

69. In addition to paying cash to Defendants every night, Dancers were required to tip 

out other employees, which could include bartenders, other server personnel, and bouncers. 

70. Defendants were responsible for providing the locker rooms, dance stages 

(including poles), DJ, and music used by dancers. 

71. Defendants did not require that Dancers have any special skills in order to obtain 

employment. 

72. Defendant BACE Ohio is an entertainment club lobbying trade association (ran 

by club owners) that many gentlemen’s clubs across the State of Ohio are members. 

73. Defendants, in part through BACE Ohio, employed a tenant system whereby 

clubs deny Dancers their rightful minimum wage and require Dancers to pay various collusive, 

artificial, and illegal fees to club owners including a fee called “rent.” 

74. Defendants, in part through BACE Ohio, created and implemented a program 

Defendants were to follow. This program included paying Dancers no wages. 

75. Plaintiffs and Dancers are integral to the financial success of Defendants’ 

business including the business of BACE Ohio member clubs. 

76. Defendants participated in meetings at trade associations (and otherwise) where 

Dancer wages and programs were discussed. 

77. Use of the tenant agreement is a naked wage fixing agreement and is per se illegal 

under antitrust laws. 

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78. According to the FTC, competition among employers helps actual and potential 

employees through higher wages, better benefits, and other terms of employment. Defendants 

stifled the bettering of employment conditions as they agreed not to compete. 

79. Defendants’ activities constitute wage fixing in violation of anti-trust laws. 

Defendants maintained written wage fixing agreements i.e., all tenant agreements fix wages at 

zero. 

80. Defendants made no public disclosures before sharing wage and employment 

information. 

81. BACE Ohio, upon information and belief, maintains records and data about other 

clubs that reveals the information to further the Coconspirator Defendants’ anticompetitive 

mission. This data includes Defendants internal wage and compensation information. 

82. Defendants all agreed that they would provide Dancers the same benefits—none. 

83. But for Defendants’ anticompetitive activity, Dancers would be paid at least the 

minimum required wages by law. 

84. These agreements create a logical decrease in competition, as only a limited 

number of individuals would be willing to undertake such oppressive pay schemes. Moreover, 

competition would clearly grow if wages were competitive and no agreement existed to 

artificially depress wages. 

85. The practices and policies set by Defendants resulted in Plaintiffs being paid less 

than the required minimum wage. 

FLSA ALLEGATIONS 

86. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

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87. The following allegations are asserted against the Wage and Hour Defendants (the 

Doll House Defendants, House of Babes Defendants, Private Dancer Defendants, and Club X 

Defendants) as if alleged against each Defendant individually herein. 

88. The FLSA is to be construed expansively in favor of coverage, recognizing that 

broad coverage is essential to accomplish the goals of this remedial legislation, including the 

avoidance of unfair competition. 

89. To determine employment status under the FLSA’s broad remedial purpose, 

courts apply some form of the economic realities test to determine whether as a matter of 

economic reality, the individuals are dependent upon the business to which they render service. 

90. The FLSA applied to Plaintiffs and the putative Collective Action Members at all 

times that they worked as Dancers at the Wage and Hour Defendants’ clubs. 

91. No exemptions to the application of the FLSA apply to Plaintiffs or the putative 

Collective Action Members. For instance, neither Plaintiffs nor any putative Collective Action 

Member has ever been a professional or artist exempt from the provisions of the FLSA. The 

dancing required by the Wage and Hour Defendants does not require invention, imagination or 

talent in a recognized field of artistic endeavor and Plaintiffs and the putative Collective Action 

Members have never been compensated by the Wage and Hour Defendants on a set salary, wage, 

or fee basis. Rather, Plaintiffs and the putative Collective Action Members’ sole source of 

income while working for the Wage and Hour Defendants was tips given to them by the clubs’ 

patrons (i.e., stage dancing or single dancing tips). 

92. At all relevant times, Plaintiffs and the putative Collective Action Members were 

employees of their respective Wage and Hour Defendant pursuant to the FLSA. 

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93. During the relevant time period, neither Plaintiffs nor any putative Collective 

Action Member received money from the Wage and Hour Defendants in the form of wages, nor 

did they receive any other category of compensation (e.g., bonuses, shift differentials, per diem 

payments) from the Wage and Hour Defendants. 

94. The money that Plaintiffs and the putative Collective Action Members would 

receive from customers at the Wage and Hour Defendants location is a tip, not a service charge 

as those terms are defined in relevant FLSA regulations. See 29 C.F.R. §§ 531.52, 531.53, & 

531.55. 

95. Those tips received by Plaintiffs and the putative Collective Action Members do 

not become part of the Wage and Hour Defendants’ gross receipts to be later distributed to the 

Dancers at a given location as wages. Instead, Dancers merely pay the club a portion of their tips. 

96. Plaintiffs and the putative Collective Action Members are tipped employees under 

the FLSA, as they are engaged in an occupation in which they customarily and regularly receive 

more than $30 per month in tips. See 29 U.S.C. § 203(t). 

97. The Wage and Hour Defendants, however, are not entitled to take a tip credit for 

the amounts Plaintiffs and the putative Collective Action Members received as tips. 29 U.S.C. § 

203(m) require an employer to inform its employee that it intends to rely on the tip credit to 

satisfy its minimum wage obligations. Here, the Wage and Hour Defendants affirmatively 

informed Plaintiffs and the Collective Action Members that they would not be paid wages at all, 

much less paid a tip credit adjusted minimum wage. 

98. The Wage and Hour Defendants’ scheme to label Plaintiffs and the putative 

Collective Action Members as independent contractors was designed to deny them their 

fundamental rights as employees to receive minimum wages, overtime, to demand and retain 

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portions of tips given to putative Collective Action Members by the Wage and Hour Defendants’ 

customers, and to enhance profits. 

99. The Wage and Hour Defendants’ illegal scheme to label Plaintiffs and the 

putative Collective Action Members as independent contractors rather than employees was 

willful. 

100. Finally, federal law requires employers to make and keep accurate and detailed 

payroll data for non-exempt employees. 29 U.S.C. § 211(c); 29 C.F.R. § 516.2. Amongst other 

things, the regulations require employers to make and keep payroll records showing data such as 

the employee’s name, social security number, occupation, time of day and day of week which the 

workweek begins, regular hourly rate of pay for any week in which overtime pay is due, hours 

worked each workday and total hours worked each workweek, total daily or weekly straight time 

earnings, total premium pay for overtime hours, total wages paid each pay period and date of 

payment and pay period covered by the payment, and records of remedial payments. 29 C.F.R. § 

516.2(a)&(b). Employers are required to maintain the foregoing data for a minimum of three 

years. 29 C.F.R. § 516.5. The Wage and Hour Defendants failed to accurately keep the 

aforementioned records. 

COLLECTIVE ACTION ALLEGATIONS 

101. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

102. The following allegations are asserted against the Wage and Hour Defendants (the 

Doll House Defendants, House of Babes Defendants, Private Dancer Defendants, and Club X 

Defendants) as if alleged against each Defendant individually herein. 

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103. Plaintiffs bring this collective action on behalf of themselves and all other 

similarly situated Dancers. 

104. Plaintiffs have actual knowledge that putative Collective Action Members have 

been denied wages for all hours worked in each workweek. Plaintiffs worked with other Dancers 

at the Wage and Hour Defendants’ clubs. As such, they have personal knowledge of the pay 

violations. Furthermore, other Dancer employees at the Wage and Hour Defendants’ 

establishments have shared with them that they experienced similar pay violations as those 

described in this complaint. 

105. The Wage and Hour Defendants misclassified Plaintiffs and similarly-situated 

Collective Action Members as independent contractors to avoid obligation to pay them pursuant 

to the FLSA. 

106. Plaintiffs are not exempt from the overtime and minimum wage requirements 

under the FLSA. 

107. Plaintiffs and the Collective Action Members were subject to the same uniform 

illegal pay practices and policies. Each Wage and Hour Defendant maintained a single common 

and unified illegal pay policy that applied to all Dancers equally and failed to pay them the 

wages they were entitled to under law. The Wage and Hour Defendants erroneously classified 

Dancers as independent contractors. 

108. The Wage and Hour Defendants’ illegal pay practices and policies are identified 

above and generally include failing to pay minimum wage for each hour worked, subjecting 

workers to an illegal tip pool policy, and charging money to employees for performing their 

essential job functions. 

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109. The putative Collective Action Members are similarly situated to Plaintiffs in all 

relevant respects having performed the same work duties as Plaintiffs and being similarly 

situated with regard to the Wage and Hour Defendants policies and pay practices. 

110. The putative Collective Action Members regularly work or have worked in excess 

of forty hours during a workweek. 

111. The specific job titles or precise job responsibilities of each putative Collective 

Action Member does not prevent collective treatment. 

112. The Collective Action Members are owed wages for the same reasons as 

Plaintiffs. 

113. Application of Defendants’ illegal pay practices does/did not depend on the 

personal circumstances of Plaintiffs or putative Collective Action Members. Rather, the same 

policy or practice which resulted in the non-payment of minimum and overtime wages applies to 

all putative Collective Action Members. Accordingly, Plaintiffs seeks to represent collective 

actions. 

114. Plaintiffs Jane Does 1 and 2 seek to represent, and are similarly situated to, the 

following group: Doll House Collective Action. All of the Doll House Defendants’ current 

and former Dancers who are or were employed with the Doll House Defendants during the 

three years before this Complaint was filed up to the present.

115. Plaintiff Jane Doe 3 seeks to represent, and are similarly situated to, the following 

group: House of Babes Collective Action. All of the House of Babes Defendants’ current and 

former Dancers who are or were employed with the House of Babes Defendants during the 

three years before this Complaint was filed up to the present.

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116. Plaintiff Jane Doe 2 seeks to represent, and are similarly situated to, the following 

group: Club X Collective Action. All of the Club X Defendants’ current and former 

Dancers who are or were employed with the Club X Defendants during the three years 

before this Complaint was filed up to the present.

117. Plaintiff Jane Doe 2 seeks to represent, and are similarly situated to, the following 

group: Private Dancer Collective Action. All of the Private Dancer Defendants’ current and 

former Dancers who are or were employed with the Private Dancer Defendants during the 

three years before this Complaint was filed up to the present.

118. The Wage and Hour Defendants knowingly, willfully, and with reckless disregard 

for the rights of putative Collective Action Members carried out an illegal pattern or practice of 

failing to pay minimum wages and overtime compensation. 

119. Defendants did not act in good faith or reliance upon and of the following in 

formulating its pay practices: (a) case law, (b) the FLSA, (c) Department of Labor Wage & Hour 

Opinion Letters or (d) the Code of Federal Regulations. 

120. Defendants acted willfully in failing to pay Plaintiffs and putative Collective 

Action Members in accordance with the law. 

OHIO WAGE LAW ALLEGATIONS 

121. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

122. The following allegations are asserted against the Wage and Hour Defendants (the 

Doll House Defendants, House of Babes Defendants, Private Dancer Defendants, and Club X 

Defendants) as if alleged against each Defendant individually herein. 

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123. The OMFWSA, O.R.C. §§ 4111.01, et seq., expressly incorporates the standards 

set forth under the FLSA. 

124. Ohio law requires employers to pay employees minimum and overtime wages at a 

rate of one and one-half times the employee’s regular rate of pay for all hours worked in excess 

of forty hours in one workweek. O.R.C. §§ 4111.01, et seq.

125. Ohio law requires employers to maintain accurate pay records. O.R.C. § 4111.08. 

126. Ohio law requires employers to, on or before the first day of each month, pay all 

its employees the wages earned by them during the first half of the preceding month ending with 

the fifteenth day thereof, and shall, on or before the fifteenth day of each month, pay such 

employees the wages earned by them during the last half of the preceding calendar month. 

O.R.C. § 4113.15. 

127. Ohio common law prohibits the windfall of unjust enrichment. 

WAGE AND HOUR CLASS ACTION ALLEGATIONS 

128. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

129. The following allegations are asserted against the Wage and Hour Defendants (the 

Doll House Defendants, House of Babes Defendants, Private Dancer Defendants, and Club X 

Defendants) as if alleged against each Defendant individually herein. 

130. Plaintiffs bring their claims for relief under Ohio law on behalf of themselves and 

a Class of persons under Rules 23(a), (b)(2), and (3) of the Federal Rules of Civil Procedure.

131. Plaintiffs Jane Does 1 and 2 seek to represent a class as defined as follows:

Doll House Class. All of the Doll House Defendants’ current and 

former Dancers who are or were employed with the Doll House 

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Defendants during the six years before this Complaint was filed up to 

the present. 

132. Plaintiffs Jane Doe 3 seeks to represent a class as defined as follows:

House of Babes Class. All of the House of Babes Defendants’ current 

and former Dancers who are or were employed with the House of 

Babes Defendants during the six years before this Complaint was filed 

up to the present. 

133. Plaintiffs Jane Doe 2 seeks to represent a class as defined as follows:

Private Dancer Class. All of the Private Dancer Defendants’ current 

and former Dancers who are or were employed with the Private 

Dancer Defendants during the six years before this Complaint was 

filed up to the present. 

134. Plaintiffs Jane Doe 2 seeks to represent a class as defined as follows:

Club X Class. All of the Club X Defendants’ current and former 

Dancers who are or were employed with the Club X Defendants 

during the six years before this Complaint was filed up to the present. 

135. Numerosity (FED. R. CIV. P. 23(a)(1)). In each of the proposed classes, the 

putative Class Action Members are so numerous that joinder of all members is impracticable. 

The precise number of such persons is unknown, and the facts on which that number can be 

ascertained are presently within the sole control of the Wage and Hour Defendants. Upon 

information and belief, there are over forty putative Class Action Members at each of the Wage 

and Hour Defendants Clubs.

136. Commonality (FED. R. CIV. P. 23(a)(2)).For each proposed class, common 

questions of law and fact exist as to putative Class Action Members, including, but not limited 

to, the following: 

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a. Whether the Wage and Hour Defendants misclassified Dancers as independent 

contractors; 

b. Whether the Wage and Hour Defendants failed to pay wages including 

overtime pursuant to O.R.C. §§ 4111.01 et seq.; 

c. Whether the Wage and Hour Defendants failed to keep records pursuant to 

O.R.C. § 4111.08; 

d. Whether the Wage and Hour Defendants failed to timely pay Class Members in 

accordance with O.R.C. § 4113.15; 

e. Whether the Wage and Hour Defendants was unjustly enriched by work and 

services performed by Class Members; and 

f. The proper measure of damages sustained by each putative Class. 

137. Typicality (FED. R. CIV. P. 23(a)(3)). The representative Plaintiffs’ claims, for 

each proposed class, are typical of those of the putative Class Action Members. Plaintiffs, like 

other Class Action Members, were subjected to a policy and practice of refusing to pay wages 

owed to Dancers in accordance with Ohio law. 

138. Adequacy (FED. R. CIV. P. 23(a)(4)). Each Plaintiff is able to adequately 

represent and protect the interests of the putative class which she seeks to serve as a 

representative. 

139. Adequacy of counsel (FED. R. CIV. P. 23(g). Plaintiffs have retained counsel 

competent and experienced in complex class actions, the FLSA, and state labor and employment 

litigation.

140. Certification of the Ohio claims is appropriate pursuant to FED. R. CIV. P. 

23(b)(2) for each class because each Wage and Hour Defendant has acted or refused to act on 

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grounds generally applicable to its respective putative Class, making appropriate declaratory and 

injunctive relief with respect to the Plaintiffs and the putative Class Action Members as a whole. 

141. Predominance and Superiority (FED. R. CIV. P. 23(b)(3)). Class certification 

of the Ohio classes is also appropriate under FED. R. CIV. P. 23(b)(3) because questions of law 

and fact common to the putative Class Action Members predominate over any questions 

affecting only individual members of the putative Class Action, and because a class action is 

superior to other available methods for the fair and efficient adjudication of this litigation. The 

Wage and Hour Defendants’ common and uniform policies and practices unlawfully fail to 

compensate the members of the putative Classes. The damages suffered by individual members 

of the putative Classes are small compared to the expense and burden of individual prosecution 

of this litigation. In addition, class certification is superior because it will obviate the need for 

unduly duplicative litigation which might result in inconsistent judgments about the Wage and 

Hour Defendants practices. 

142. Notice (FED. R. CIV. P. 23(c)(2)(B)).Plaintiffs intend to send opt-out notice to 

all members of the putative Class to the extent provided by Rule 23. 

143. Plaintiffs’ claims are typical of the claims of the Classes, and a class action is 

superior to other available methods of fair and efficient adjudication of the controversyparticularly in the context of wage and hour litigation where individual plaintiffs lack the 

financial resources to vigorously prosecute a lawsuit in federal court against corporate 

defendants. 

STATEWIDE CONSPIRACY CLASS ACTION ALLEGATIONS 

144. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

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145. Plaintiffs bring their claims for relief under Federal and Ohio law on behalf of 

themselves and all others similarly situated Dancers against a statewide group of coconspirator 

Defendants throughout Ohio that have used and / or are using the Dancer-Tenant Lease 

Agreements under Rules 23(a), (b)(2), and (3) of the Federal Rules of Civil Procedure.

146. Plaintiffs and all putative Statewide Plaintiff Class Action Members are all 

Dancers subject to the same illegal pay practices and policies applicable to all of the statewide 

Defendant Class’s Dancers. Plaintiffs seek to represent the following statewide Plaintiff Class:

Statewide Conspiracy Class. All current and former Dancers 

employed by Defendants within the six years before this Complaint 

was filed up to the present. 

147. Numerosity (FED. R. CIV. P. 23(a)(1)). The Statewide Conspiracy Class is so 

numerous that joinder of all members is impracticable. The precise number of such persons is 

unknown, and the facts on which that number can be ascertained are presently within the sole 

control of the Defendants. Upon information and belief, there are thousands of putative 

Statewide Conspiracy Class Action Members.

148. Commonality (FED. R. CIV. P. 23(a)(2)). Common questions of law and fact 

exist as to putative Statewide Conspiracy Class Action Members including, but not limited to, 

the following: 

a. Whether Defendants conspired to violate federal and state antitrust laws by 

fixing or restraining payments to members of the putative Statewide Conspiracy Class 

through the use of the tenant system; 

b. Whether Defendants conspired to violate federal and state antitrust laws by 

sharing non-public wage information related to the putative Statewide Conspiracy Class 

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through the use of the tenant system, documents related to the system, and meetings in 

furtherance of implementing the system; 

c. Whether the tenant system is unlawful under Ohio and federal wage and hour 

laws. Whether the tenant system denied the members of the putative statewide Plaintiff 

Class their rightful wages, and exacted illegal payments, including “rent” from the 

Members of the Statewide Conspiracy Class; 

d. Whether this conspiracy was unlawful; 

e. Whether Defendants unlawful actions should be enjoined; and 

f. The proper measure of damages sustained by the putative Statewide Conspiracy 

Class. 

149. Typicality (FED. R. CIV. P. 23(a)(3)). Plaintiffs’ claims are typical of those of 

the putative Statewide Conspiracy Class Action Members. Plaintiffs, like other Statewide 

Conspiracy Class Action Members, were subjected to Defendants’ policies and practices of 

refusing to pay wages owed to its Dancers in accordance with Ohio law.

150. Adequacy (FED. R. CIV. P. 23(a)(4)). Plaintiffs will fairly and adequately 

represent and protect the interests of the putative Class.

151. Adequacy of counsel (FED. R. CIV. P. 23(g). Plaintiffs have retained counsel 

competent and experienced in complex class actions, the FLSA, and state labor and employment 

litigation.

152. Class certification of the Statewide Conspiracy Class claims is appropriate 

pursuant to FED. R. CIV. P. 23(b)(2) because Defendants have acted or refused to act on 

grounds generally applicable to the putative Statewide Conspiracy Class, making appropriate 

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declaratory and injunctive relief with respect to the Plaintiffs and the putative Statewide 

Conspiracy Class Action Members as a whole. 

153. Predominance and Superiority (FED. R. CIV. P. 23(b)(3)). Class certification 

of the Statewide Conspiracy Class claims is also appropriate under FED. R. CIV. P. 23(b)(3) 

because questions of law and fact common to the putative Statewide Conspiracy Class Action 

Members predominate over any questions affecting only individual members of the putative 

Statewide Conspiracy Class Action, and because a class action is superior to other available 

methods for the fair and efficient adjudication of this litigation. The group of Ohio Defendants’ 

common and uniform policies and practices unlawfully fail to compensate the members of the 

putative Statewide Conspiracy Class. The damages suffered by individual members of the 

putative Statewide Conspiracy Class are small compared to the expense and burden of individual 

prosecution of this litigation. In addition, class certification is superior because it will obviate the 

need for unduly duplicative litigation which might result in inconsistent judgments about the 

practices of Defendants.

154. Notice (FED. R. CIV. P. 23(c)(2)(B)). Plaintiffs intend to send opt-out notice to 

all members of the putative Statewide Conspiracy Class to the extent provided by Rule 23. 

155. Plaintiffs’ claims are typical of the claims of the Statewide Conspiracy Class, and 

a class action is superior to other available methods of fair and efficient adjudication of the 

controversy - particularly in the context of wage and hour litigation where individual plaintiffs 

lack the financial resources to vigorously prosecute a lawsuit in federal court against corporate 

defendants. 

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CAUSES OF ACTION 

First Claim: Fair Labor Standards Act: Failure to Pay Minimum Wages and Overtime 

Against Doll House Defendants 

(On Behalf Of the Doll House Collective Action Members) 

156. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

157. The foregoing conduct, as alleged, violated the FLSA. 

158. Plaintiffs Jane Does 1 and 2, and the putative Doll House Collective Action 

Members, are nonexempt employees entitled to be paid overtime compensation for all overtime 

hours worked, as defined above. See 29 U.S.C. § 203(e)(1). 

159. Defendant Doll House was, and is, required to pay its employees, Plaintiffs Jane 

Does 1 and 2, and the putative Doll House Collective Action Members, at least the minimum 

wage for all hours worked under forty in a given workweek. 29 U.S.C. § 206. 

160. Defendant Doll House was, and is, required to pay its employees, Plaintiffs Jane 

Does 1 and 2,and the putative Doll House Collective Action Members, overtime premiums in an 

amount of one and one half times their regular rate of pay for all hours worked over forty hours 

in a given workweek. 29 U.S.C. § 207. 

161. Defendant Doll House failed to pay Plaintiffs Jane Does 1 and 2, and the putative 

Doll House Collective Action Members their federally mandated overtime wages for all hours 

worked over forty in a given workweek. 

162. Defendant Doll House also unlawfully retained certain tips. Those tips were the 

sole property of Plaintiffs Jane Does 1 and 2, and the putative Doll House Collective Action 

Members, and were not made part of Defendant’s gross receipts. 29 C.F.R. §§ 531.52, 531.53, & 

531.55. 

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163. No tip credit applies to reduce or offset Defendant Doll House’s liability under 

the FLSA, because Defendant did not inform Plaintiffs Jane Does 1 and 2, and the putative Doll 

House Collective Action Members that it would be applying a tip credit to satisfy a portion of the 

statutory minimum wage, nor did Plaintiffs Jane Does 1 and 2, and the putative Doll House 

Collective Action Members retain all tips, except those included in a tipping pool among 

employees who customarily receive tips. 29 U.S.C. § 203(m). 

164. Accordingly, Plaintiffs Jane Does 1 and 2, and the putative Doll House Collective 

Action Members are entitled to the full statutory minimum wages set forth in 29 U.S.C. § 206 & 

207. 

165. Defendant Doll House’s conduct was willful and done to avoid paying minimum 

wages and overtime. 29 U.S.C. § 255(a). Therefore, Plaintiffs Jane Does 1 and 2, and the 

putative Doll House Collective Action Members are entitled to a three (3) year statute of 

limitations. 

166. Plaintiffs Jane Does 1 and 2, and the putative Doll House Collective Action 

Members seek all damages to which they are entitled under the FLSA, including their back 

minimum wages, back overtime wages, liquidated damages, attorneys’ fees and costs, postjudgment interest, and specifically plead recovery for the three (3) year period preceding the 

filing of this lawsuit through its resolution. 

167. Defendant Doll House failed to pay Plaintiffs Jane Does 1 and 2, and the putative 

Doll House Collective Action Members the federally-mandated minimum wage for all hours 

worked under forty in a given workweek. Moreover, Defendant Doll House did not pay any 

overtime; it did not pay Plaintiffs Jane Does 1 and 2, or the Doll House Collective Action 

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Members at all. Accordingly, Defendant Doll House violated the FLSA minimum wage and 

overtime provisions. 

Second Claim: Fair Labor Standards Act: Failure to Pay Minimum Wages and Overtime 

Against House of Babes Defendants 

(On Behalf Of the House of Babes Collective Action Members) 

168. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

169. The foregoing conduct, as alleged, violated the FLSA. 

170. Plaintiff Jane Doe 3 and the putative House of Babes Collective Action Members 

are nonexempt employees entitled to be paid overtime compensation for all overtime hours 

worked, as defined above. See 29 U.S.C. § 203(e)(1). 

171. House of Babes Defendants were, and are, required to pay employees, Plaintiff 

Jane Doe 3 and the putative House of Babes Collective Action Members, at least the minimum 

wage for all hours worked under forty in a given workweek. 29 U.S.C. § 206. 

172. House of Babes Defendants were, and are, required to pay employees, Plaintiff 

Jane Doe 3 and the putative House of Babes Collective Action Members, overtime premiums in 

an amount of one and one half times their regular rate of pay for all hours worked over forty 

hours in a given workweek. 29 U.S.C. § 207. 

173. House of Babes Defendants failed to pay Plaintiff Jane Doe 3 and the putative 

House of Babes Collective Action Members their federally mandated overtime wages for all 

hours worked over forty in a given workweek. 

174. House of Babes Defendants also unlawfully retained certain tips. Those tips were 

the sole property of Plaintiff Jane Doe 3 and the putative House of Babes Collective Action 

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Members, and were not made part of House of Babes Defendants’ gross receipts. 29 C.F.R. §§ 

531.52, 531.53, & 531.55. 

175. No tip credit applies to reduce or offset House of Babes Defendants’ liability 

under the FLSA, because Defendants did not inform Plaintiff Jane Does 3 and the putative House 

of Babes Collective Action Members a tip credit applied to satisfy a portion of the statutory 

minimum wage, nor did Plaintiff Jane Doe 3 and the putative House of Babes Collective Action 

Members retain all tips, except those included in a tipping pool among employees who 

customarily receive tips. 29 U.S.C. § 203(m). 

176. Accordingly, Plaintiff Jane Doe 3 and the putative House of Babes Collective 

Action Members are entitled to the full statutory minimum wages set forth in 29 U.S.C. § 206 & 

207. 

177. House of Babes Defendants’ conduct was willful and done to avoid paying 

minimum wages and overtime. 29 U.S.C. § 255(a). Therefore, Plaintiff Jane Doe 3 and the 

putative House of Babes Collective Action Members are entitled to a three (3) year statute of 

limitations. 

178. Plaintiff Jane Doe 3 and the putative House of Babes Collective Action Members 

seek all damages to which they are entitled under the FLSA, including their back minimum 

wages, back overtime wages, liquidated damages, attorneys’ fees and costs, post-judgment 

interest, and specifically plead recovery for the three (3) year period preceding the filing of this 

lawsuit through its resolution. 

179. House of Babes Defendants failed to pay Plaintiff Jane Doe 3 and the putative 

House of Babes Collective Action Members the federally-mandated minimum wage for all hours 

worked under forty in a given workweek. Moreover, House of Babes Defendants did not pay any 

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overtime; it did not pay Plaintiff Jane Doe 3 or the House of Babes Collective Action Members 

at all. Accordingly, House of Babes Defendants violated the FLSA minimum wage and overtime 

provisions. 

Third Claim: Fair Labor Standards Act: Failure to Pay Minimum Wages and Overtime 

Against Private Dancer Defendants 

(On Behalf Of the Private Dancer Collective Action Members) 

180. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

181. The foregoing conduct, as alleged, violated the FLSA. 

182. Plaintiff Jane Doe 2and the putative Private Dancer Collective Action Members 

are nonexempt employees entitled to be paid overtime compensation for all overtime hours 

worked, as defined above. See 29 U.S.C. § 203(e)(1). 

183. Private Dancer Defendants were, and are, required to pay employees, Plaintiff 

Jane Doe 2 and the putative Private Dancer Collective Action Members, at least the minimum 

wage for all hours worked under forty in a given workweek. 29 U.S.C. § 206. 

184. Private Dancer Defendants were, and are, required to pay employees, Plaintiff 

Jane Doe 2 and the putative Private Dancer Collective Action Members, overtime premiums in 

an amount of one and one half times their regular rate of pay for all hours worked over forty 

hours in a given workweek. 29 U.S.C. § 207. 

185. Private Dancer Defendants failed to pay Plaintiff Jane Doe 2 and the putative 

Private Dancer Collective Action Members their federally mandated overtime wages for all 

hours worked over forty in a given workweek. 

186. Private Dancer Defendants also unlawfully retained certain tips. Those tips were 

the sole property of Plaintiff Jane Doe 2and the putative Private Dancer Collective Action 

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Members, and were not made part of Private Dancer Defendants’ gross receipts. 29 C.F.R. §§ 

531.52, 531.53, & 531.55. 

187. No tip credit applies to reduce or offset Private Dancer Defendants’ liability under 

the FLSA, because Defendants did not inform Plaintiff Jane Does 2 and the putative Private 

Dancer Collective Action Members a tip credit applied to satisfy a portion of the statutory 

minimum wage, nor did Plaintiff Jane Doe 2 and the putative Private Dancer Collective Action 

Members retain all tips, except those included in a tipping pool among employees who 

customarily receive tips. 29 U.S.C. § 203(m). 

188. Accordingly, Plaintiff Jane Doe 2 and the putative Private Dancer Collective 

Action Members are entitled to the full statutory minimum wages set forth in 29 U.S.C. § 206 & 

207. 

189. Private Dancer Defendants’ conduct was willful and done to avoid paying 

minimum wages and overtime. 29 U.S.C. § 255(a). Therefore, Plaintiff Jane Doe 2 and the 

putative Private Dancer Collective Action Members are entitled to a three (3) year statute of 

limitations. 

190. Plaintiff Jane Doe 2 and the putative Private Dancer Collective Action Members 

seek all damages to which they are entitled under the FLSA, including their back minimum 

wages, back overtime wages, liquidated damages, attorneys’ fees and costs, post-judgment 

interest, and specifically plead recovery for the three (3) year period preceding the filing of this 

lawsuit through its resolution. 

191. Private Dancer Defendants failed to pay Plaintiff Jane Doe 2 and the putative 

Private Dancer Collective Action Members the federally-mandated minimum wage for all hours 

worked under forty in a given workweek. Moreover, Private Dancer Defendants did not pay any 

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overtime; it did not pay Plaintiff Jane Doe 2 or the Private Dancer Collective Action Members at 

all. Accordingly, Private Dancer Defendants violated the FLSA minimum wage and overtime 

provisions. 

Fourth Claim: Fair Labor Standards Act: Failure to Pay Minimum Wages and Overtime 

Against Club X Defendants 

(On Behalf Of the Club X Collective Action Members) 

192. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

193. The foregoing conduct, as alleged, violated the FLSA. 

194. Plaintiff Jane Doe 2 and the putative Club X Collective Action Members are 

nonexempt employees entitled to be paid overtime compensation for all overtime hours worked, 

as defined above. See 29 U.S.C. § 203(e)(1). 

195. Club X Defendants were, and are, required to pay employees, Plaintiff Jane Doe 2 

and the putative Club X Collective Action Members, at least the minimum wage for all hours 

worked under forty in a given workweek. 29 U.S.C. § 206. 

196. Club X Defendants were, and are, required to pay employees, Plaintiff Jane Doe 2 

and the putative Club X Collective Action Members, overtime premiums in an amount of one 

and one half times their regular rate of pay for all hours worked over forty hours in a given 

workweek. 29 U.S.C. § 207. 

197. Club X Defendants failed to pay Plaintiff Jane Doe 2 and the putative Club X 

Collective Action Members their federally mandated overtime wages for all hours worked over 

forty in a given workweek. 

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198. Club X Defendants also unlawfully retained certain tips. Those tips were the sole 

property of Plaintiff Jane Doe 2 and the putative Club X Collective Action Members, and were 

not made part of Club X Defendants’ gross receipts. 29 C.F.R. §§ 531.52, 531.53, & 531.55. 

199. No tip credit applies to reduce or offset Club X Defendants’ liability under the 

FLSA, because Defendants did not inform Plaintiff Jane Doe 2 and the putative Club X 

Collective Action Members a tip credit applied to satisfy a portion of the statutory minimum 

wage, nor did Plaintiff Jane Doe 2and the putative Club X Collective Action Members retain all 

tips, except those included in a tipping pool among employees who customarily receive tips. 29 

U.S.C. § 203(m). 

200. Accordingly, Plaintiff Jane Doe 2 and the putative Club X Collective Action 

Members are entitled to the full statutory minimum wages set forth in 29 U.S.C. § 206 & 207. 

201. Club X Defendants’ conduct was willful and done to avoid paying minimum 

wages and overtime. 29 U.S.C. § 255(a). Therefore, Plaintiff Jane Doe 2 and the putative Club X 

Collective Action Members are entitled to a three (3) year statute of limitations. 

202. Plaintiff Jane Doe 2 and the putative Club X Collective Action Members seek all 

damages to which they are entitled under the FLSA, including their back minimum wages, back 

overtime wages, liquidated damages, attorneys’ fees and costs, post-judgment interest, and 

specifically plead recovery for the three (3) year period preceding the filing of this lawsuit 

through its resolution. 

203. Club X Defendants failed to pay Plaintiff Jane Doe 2 and the putative Club X 

Collective Action Members the federally-mandated minimum wage for all hours worked under 

forty in a given workweek. Moreover, Club X Defendants did not pay any overtime; it did not 

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pay Plaintiff Jane Doe 2 or the Club X Collective Action Members at all. Accordingly, Club X 

Defendants violated the FLSA minimum wage and overtime provisions. 

Fifth claim: Ohio Minimum Fair Wage Act Violations- Failure to Pay Minimum Wages 

and Overtime Wages O.R.C. § 4111.01, et seq. 

Against Doll House Defendants 

(On Behalf Of the Doll House Class Action Members) 

204. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

205. Defendant Doll House failed to pay wages including overtime to Plaintiffs Jane 

Does 1 and 2, and putative Doll House Class Action Members. 

206. Defendant Doll House’s failure to pay proper minimum and overtime wages to 

Plaintiffs Jane Does 1 and 2, and putative Doll House Class Action Members for each hour 

worked including but not limited to those hours worked in excess of forty hours per week was 

willful within the meaning of the Ohio Minimum Fair Wage Standards Act and in reckless 

disregard of applicable law. 

207. Plaintiffs Jane Does 1 and 2, on behalf of themselves and the putative Doll House 

Class Action Members, seek restitution in the amount of the respective unpaid overtime wages 

earned and due at a rate of not less than one and one half times the regular rate of pay for all 

hours worked over forty in a given workweek. 

208. As a result of Defendant Doll House’s illegal actions, Plaintiffs Jane Does 1 and 2 

thereon as well Doll House Class Action Members suffered lost wages and other losses such as 

incurring the costs of attorneys’ fees associated with this action. Thus, they seek attorneys’ fees. 

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Sixth claim: Ohio Minimum Fair Wage Act Violations- Failure to Pay Minimum Wages 

and Overtime Wages O.R.C. § 4111.01, et seq. 

Against House of Babes Defendants 

(On Behalf Of the House of Babes Class Action Members) 

209. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

210. House of Babes Defendants failed to pay wages including overtime to Plaintiff 

Jane Doe 3 and putative House of Babes Class Action Members. 

211. House of Babes Defendants’ failure to pay proper minimum and overtime wages 

to Plaintiff Jane Doe 3 and putative House of Babes Class Action Members for each hour worked 

including but not limited to those hours worked in excess of forty hours per week was willful 

within the meaning of the Ohio Minimum Fair Wage Standards Act and in reckless disregard of 

applicable law. 

212. Plaintiff Jane Doe 3, on behalf of herself and the putative House of Babes Class 

Action Members, seek restitution in the amount of the respective unpaid overtime wages earned 

and due at a rate of not less than one and one half times the regular rate of pay for all hours 

worked over forty in a given workweek. 

213. As a result of House of Babes Defendants’ illegal actions, Plaintiffs Jane Doe 3 

thereon as well House of Babes Class Action Members suffered lost wages and other losses such 

as incurring the costs of attorneys’ fees associated with this action. Thus, they seek attorneys’ 

fees. 

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Seventh claim: Ohio Minimum Fair Wage Act Violations- Failure to Pay Minimum Wages 

and Overtime Wages O.R.C. § 4111.01, et seq. 

Against Private Dancer Defendants 

(On Behalf Of the Private Dancer Class Action Members) 

214. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

215. Private Dancer Defendants failed to pay wages including overtime to Plaintiff 

Jane Doe 2 and putative Private Dancer Class Action Members. 

216. Private Dancer Defendants’ failure to pay proper minimum and overtime wages to 

Plaintiff Jane Doe 2 and putative Private Dancer Class Action Members for each hour worked 

including but not limited to those hours worked in excess of forty hours per week was willful 

within the meaning of the Ohio Minimum Fair Wage Standards Act and in reckless disregard of 

applicable law. 

217. Plaintiff Jane Doe 2, on behalf of herself and the putative Private Dancer Class 

Action Members, seek restitution in the amount of the respective unpaid overtime wages earned 

and due at a rate of not less than one and one half times the regular rate of pay for all hours 

worked over forty in a given workweek. 

218. As a result of Private Dancer Defendants’ illegal actions, Plaintiffs Jane Doe 2 

thereon as well Private Dancer Class Action Members suffered lost wages and other losses such 

as incurring the costs of attorneys’ fees associated with this action. Thus, they seek attorneys’ 

fees. 

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Eighth claim: Ohio Minimum Fair Wage Act Violations- Failure to Pay Minimum Wages 

and Overtime Wages O.R.C. § 4111.01, et seq. 

Against Club X Defendants 

(On Behalf Of the Club X Class Action Members) 

219. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

220. Club X Defendants failed to pay wages including overtime to Plaintiff Jane Doe 2 

and putative Club X Class Action Members. 

221. Club X Defendants’ failure to pay proper minimum and overtime wages to 

Plaintiff Jane Doe 2 and putative Club X Class Action Members for each hour worked including 

but not limited to those hours worked in excess of forty hours per week was willful within the 

meaning of the Ohio Minimum Fair Wage Standards Act and in reckless disregard of applicable 

law. 

222. Plaintiff Jane Doe 2, on behalf of herself and the putative Club X Class Action 

Members, seek restitution in the amount of the respective unpaid overtime wages earned and due 

at a rate of not less than one and one half times the regular rate of pay for all hours worked over 

forty in a given workweek. 

223. As a result of Club X Defendants’ illegal actions, Plaintiffs Jane Doe 2 thereon as 

well Club X Class Action Members suffered lost wages and other losses such as incurring the 

costs of attorneys’ fees associated with this action. Thus, they seek attorneys’ fees. 

Ninth Claim: Ohio Semi-Monthly Payment Act O.R.C. § 4113.15 

Against Doll House Defendants 

(On Behalf Of the Doll House Class Action Members) 

224. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

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225. During all times material to this complaint, Defendant Doll House was an entity 

and or individual covered by the Ohio Semi-Monthly Payment Act, and Plaintiffs Jane Does 1 

and 2, and the Doll House Class Action Members are/were employed by Defendant within the 

meaning of the Ohio Semi-Monthly Payment Act. 

226. The Ohio Semi-Monthly Payment Act requires Defendant Doll House to pay 

Plaintiffs Jane Does 1 and 2, and the Doll House Class Action Members all wages, including 

unpaid overtime, and the pay that was improperly deducted, on or before the first day of each 

month, for wages earned by them during the first half of the preceding month ending with the 

fifteenth day thereof, and, on or before the fifteenth day of each month, for wages earned by 

them during the last half of the preceding calendar month. See O.R.C. § 4113.15(A). 

227. During all times relevant to this complaint, Plaintiffs Jane Does 1 and 2, and the 

Doll House Class Action Members are/were not paid wages, described as overtime wages at one 

and one-half times their regular hourly rate and the pay improperly deducted, within thirty days 

of performing the work. See O.R.C. §4113.15(B). 

228. Defendant Doll House failed to timely pay Doll House Class Action Members 

according to O.R.C. § 4113.15—indeed Defendant did not pay Doll House Class Action 

Members at all. Plaintiffs Jane Does 1 and 2, on behalf of themselves and Doll House Class 

Action Members seek wages owed and interest due pursuant to O.R.C. § 4113.15. 

Tenth Claim: Ohio Semi-Monthly Payment Act O.R.C. § 4113.15 

Against House of Babes Defendants 

(On Behalf Of the House of Babes Class Action Members) 

229. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

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230. During all times material to this complaint, House of Babes Defendants were an 

entity and or individual covered by the Ohio Semi-Monthly Payment Act, and Plaintiff Jane Doe 

3 and the House of Babes Class Action Members are/were employed by Defendant within the 

meaning of the Ohio Semi-Monthly Payment Act. 

231. The Ohio Semi-Monthly Payment Act requires House of Babes Defendants to pay 

Plaintiff Jane Doe 3, and the House of Babes Class Action Members all wages, including unpaid 

overtime, and the pay that was improperly deducted, on or before the first day of each month, for 

wages earned by them during the first half of the preceding month ending with the fifteenth day 

thereof, and, on or before the fifteenth day of each month, for wages earned by them during the 

last half of the preceding calendar month. See O.R.C. § 4113.15(A). 

232. During all times relevant to this complaint, Plaintiff Jane Doe 3, and the House of 

Babes Class Action Members are/were not paid wages, described as overtime wages at one and 

one-half times their regular hourly rate and the pay improperly deducted, within thirty days of 

performing the work. See O.R.C. §4113.15(B). 

233. House of Babes Defendants failed to timely pay House of Babes Class Action 

Members according to O.R.C. § 4113.15—indeed Defendants did not pay House of Babes Class 

Action Members at all. Plaintiff Jane Doe 3 on behalf of herself and House of Babes Class 

Action Members seek wages owed and interest due pursuant to O.R.C. § 4113.15. 

Eleventh Claim: Ohio Semi-Monthly Payment Act O.R.C. § 4113.15 

Against Private Dancer Defendants 

(On Behalf Of the Private Dancer Class Action Members) 

234. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

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235. During all times material to this complaint, Private Dancer Defendants were an 

entity and or individual covered by the Ohio Semi-Monthly Payment Act, and Plaintiff Jane Doe 

2, and the Private Dancer Class Action Members are/were employed by Defendant within the 

meaning of the Ohio Semi-Monthly Payment Act. 

236. The Ohio Semi-Monthly Payment Act requires Private Dancer Defendants to pay 

Plaintiff Jane Doe 2, and the Private Dancer Class Action Members all wages, including unpaid 

overtime, and the pay that was improperly deducted, on or before the first day of each month, for 

wages earned by them during the first half of the preceding month ending with the fifteenth day 

thereof, and, on or before the fifteenth day of each month, for wages earned by them during the 

last half of the preceding calendar month. See O.R.C. § 4113.15(A). 

237. During all times relevant to this complaint, Plaintiff Jane Doe 2, and the Private 

Dancer Class Action Members are/were not paid wages, described as overtime wages at one and 

one-half times their regular hourly rate and the pay improperly deducted, within thirty days of 

performing the work. See O.R.C. §4113.15(B). 

238. Private Dancer Defendants failed to timely pay Private Dancer Class Action 

Members according to O.R.C. § 4113.15—indeed Defendants did not pay Private Dancer Class 

Action Members at all. Plaintiff Jane Doe 2, on behalf of herself and Private Dancer Class 

Action Members seek wages owed and interest due pursuant to O.R.C. § 4113.15. 

Twelfth Claim: Ohio Semi-Monthly Payment Act O.R.C. § 4113.15 

Against Club X Defendants 

(On Behalf Of the Club X Class Action Members) 

239. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

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240. During all times material to this complaint, Club X Defendants were an entity and 

or individual covered by the Ohio Semi-Monthly Payment Act, and Plaintiff Jane Doe 2, and the 

Club X Class Action Members are/were employed by Defendant within the meaning of the Ohio 

Semi-Monthly Payment Act. 

241. The Ohio Semi-Monthly Payment Act requires Club X Defendants to pay 

Plaintiff Jane Doe 2, and the Club X Class Action Members all wages, including unpaid 

overtime, and the pay that was improperly deducted, on or before the first day of each month, for 

wages earned by them during the first half of the preceding month ending with the fifteenth day 

thereof, and, on or before the fifteenth day of each month, for wages earned by them during the 

last half of the preceding calendar month. See O.R.C. § 4113.15(A). 

242. During all times relevant to this complaint, Plaintiff Jane Doe 2, and the Club X 

Class Action Members are/were not paid wages, described as overtime wages at one and onehalf times their regular hourly rate and the pay improperly deducted, within thirty days of 

performing the work. See O.R.C. §4113.15(B). 

243. Club X Defendants failed to timely pay Club X Class Action Members according 

to O.R.C. § 4113.15—indeed Defendants did not pay Club X Class Action Members at all. 

Plaintiff Jane Doe 2, on behalf of herself and Club X Class Action Members seek wages owed 

and interest due pursuant to O.R.C. § 4113.15. 

Thirteenth Claim: Unjust Enrichment 

Against Doll House Defendants 

(On Behalf Of the Doll House Class Action Members) 

244. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

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245. Plaintiffs Jane Does 1 and 2, and the Doll House Class Action Members 

performed work and services that conferred a benefit upon Doll House Defendants were integral 

to their financial success. 

246. Defendant Doll House had knowledge that Plaintiffs Jane Does 1 and 2, and Doll 

House Class Action Members performed this work and of the benefit it incurred as a result. 

247. Defendant Doll House retained the benefit of the work and services of Plaintiffs 

Jane Does 1 and 2, and Doll House Class Action Members. 

248. Under the circumstances, retention of this benefit by Defendant Doll House would 

be unjust without payment to Plaintiffs Jane Does 1 and 2, and Doll House Class Action 

Members. 

249. Defendant Doll House was unjustly enriched and owes Plaintiffs Jane Does 1 and 

2, and Doll House Class Action Members for the retention of the benefit resulting from their 

work and services including money damages. 

Fourteenth Claim: Unjust Enrichment 

Against House of Babes Defendants 

(On Behalf Of the House of Babes Class Action Members) 

250. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

251. Plaintiff Jane Doe 3, and the House of Babes Class Action Members performed 

work and services that conferred a benefit upon House of Babes Defendants were integral to 

their financial success. 

252. House of Babes Defendants had knowledge that Plaintiff Jane Doe 3 and House 

of Babes Class Action Members performed this work and of the benefit it incurred as a result. 

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253. House of Babes Defendants retained the benefit of the work and services of 

Plaintiff Jane Doe 3, and House of Babes Class Action Members. 

254. Under the circumstances, retention of this benefit by House of Babes Defendants 

would be unjust without payment to Plaintiff Jane Doe 3 and House of Babes Class Action 

Members. 

255. House of Babes Defendants were unjustly enriched and owe Plaintiff Jane Doe 3 

and House of Babes Class Action Members for the retention of the benefit resulting from their 

work and services including money damages. 

Fifteenth Claim: Unjust Enrichment 

Against Private Dancer Defendants 

(On Behalf Of the Private Dancer Class Action Members) 

256. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

257. Plaintiff Jane Doe 2 and the Private Dancer Class Action Members performed 

work and services that conferred a benefit upon Private Dancer Defendants were integral to their 

financial success. 

258. Private Dancer Defendants had knowledge that Plaintiff Jane Doe 2 and Private 

Dancer Class Action Members performed this work and of the benefit it incurred as a result. 

259. Private Dancer Defendants retained the benefit of the work and services of 

Plaintiff Jane Doe 2 and Private Dancer Class Action Members. 

260. Under the circumstances, retention of this benefit by Private Dancer Defendants 

would be unjust without payment to Plaintiff Jane Doe 2 and Private Dancer Class Action 

Members. 

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261. Private Dancer Defendants were unjustly enriched and owe Plaintiff Jane Doe 2 

and Private Dancer Class Action Members for the retention of the benefit resulting from their 

work and services including money damages. 

Sixteenth Claim: Unjust Enrichment 

Against Club X Defendants 

(On Behalf Of the Club X Class Action Members) 

262. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

263. Plaintiff Jane Doe 2 and the Club X Class Action Members performed work and 

services that conferred a benefit upon Club X Defendants were integral to their financial success. 

264. Club X Defendants had knowledge that Plaintiff Jane Doe 2 and Club X Class 

Action Members performed this work and of the benefit it incurred as a result. 

265. Club X Defendants retained the benefit of the work and services of Plaintiff Jane 

Doe 2 and Club X Class Action Members. 

266. Under the circumstances, retention of this benefit by Club X Defendants would be 

unjust without payment to Plaintiff Jane Doe 2 and Club X Class Action Members. 

267. Club X Defendants were unjustly enriched and owe Plaintiff Jane Doe 2 and Club 

X Class Action Members for the retention of the benefit resulting from their work and services 

including money damages. 

Seventeenth Claim: Antitrust Violations 

Against Defendants 

(On Behalf Of the Statewide Conspiracy Class Action Members) 

268. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

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269. All known and unknown Defendants, which encompass gentlemen’s clubs and 

trade organizations throughout Ohio, conspired and colluded to deny Dancers in clubs across the 

state, including Plaintiffs, their rightful minimum wages and to require Dancers to pay artificial 

and illegal fees to clubs to work at clubs, such as Defendants, including a fee that is considered 

to be “rent” pursuant to a Dancer-Tenant agreement. 

270. The conspiracy was formed knowingly, voluntarily, and intentionally, and existed 

throughout the entire time period covered by this Complaint. 

271. Defendants, knowingly, voluntarily, and intentionally joined in the conspiracy. 

272. The conspiracy substantially affected interstate commerce and or occurred within 

the flow of interstate commerce. 

273. Defendants utilize a fraudulent Tenant-Dancer lease agreement. 

274. Defendants and clubs throughout the state conspired to concoct and fix, and did 

in-fact fix, the wages pay Dancers (zero) and the price of “rent” Dancers owe to clubs. 

275. Defendants and clubs throughout the state have actually exacted rent charges from 

Dancers working at their clubs. 

276. Defendants’ anticompetitive conduct has restrained or eliminated price 

competition with respect to Plaintiffs and putative Statewide Conspiracy Class Action Members. 

Plaintiffs and putative Statewide Conspiracy Class Action Members have suffered injury to their 

business or property because they have been paid less than they would have in the absence of 

Defendants’ illegal contracts and conspiracy. 

277. The conspiracy of Defendants and other unknown BACE Ohio clubs throughout 

Ohio, and the acts in furtherance of the conspiracy, constitute illegal price-fixing in violation of 

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Section 1 of the Sherman Act under 15 U.S.C. § 1 and the Ohio Valentine Act under R.C. § 

1331.01 et seq.

278. Plaintiffs and the Statewide Conspiracy Class are entitled to treble damages; 

injunctive relief barring Defendants in active concert or participation from using, promoting, 

promulgating, and / or enforcing the unlawful tenant system, and from exacting illegal “rent” and 

damages; and equitable relief in the form of full restitution of “rent” and damage charges 

unlawfully collected. 

Eighteenth Claim: Civil Conspiracy 

(On Behalf Of the Statewide Conspiracy Class Action Members) 

279. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

280. Defendants and member clubs throughout Ohio have conspired and colluded to 

deny Dancers in clubs across the state, including Plaintiffs, their rightful minimum wages in 

violation of Ohio law. 

281. Plaintiffs and the putative members Statewide Conspiracy Class are entitled to 

compensatory damages, punitive damages, and equitable restitution of all unlawfully denied 

wages, and collected “rent,” fees, and other charges. 

Nineteenth Claim: Unjust Enrichment 

(On Behalf Of the Class Action Members) 

282. Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in 

this section, unless inconsistent. 

283. Plaintiffs and the Statewide Conspiracy Class Action Members performed work 

and services that conferred a benefit upon Defendants that were integral to the financial success 

of Defendants’ businesses. 

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284. Defendants had knowledge that Plaintiffs and Statewide Conspiracy Class Action 

Members performed this work and of the benefit it incurred as a result of the conspiracy detailed 

in the allegations contained herein. 

285. Defendants retained the benefit of the work and services of Plaintiffs and 

Statewide Conspiracy Class Action Members. 

286. Under the circumstances, retention of this benefit by Defendants would be unjust 

without payment to Plaintiffs and Statewide Conspiracy Class Action Members. 

287. Defendants were unjustly enriched and owe Plaintiffs and Statewide Conspiracy 

Class Action Members for the retention of the benefit resulting from their work and services 

including money damages. 

PRAYER FOR RELIEF

Wherefore, Plaintiffs and similarly situated individuals are entitled to and pray for the 

following relief: 

A. Certification of this action as a class action pursuant to Fed.R.Civ.P.23(b)(2) 

and (3) on behalf of the (1) Doll House Class Action Members, (2) House of 

Babes Class Action Members, (3) Private Dancer Class Action Members, (4) 

Club X Class Action Members, and (5) the Statewide Conspiracy Class 

Action Members, and appointment of Plaintiffs and her counsel to represent 

the Class Action Members; 

B. Designation of this action as a collective action on behalf of (1) Doll House 

Collective Action Members, (2) House of Babes Collective Action Members, 

(3) Private Dancer Collective Action Members, (4) Club X Collective Action 

Members, and prompt issuance of notice to all similarly-situated members of 

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an opt-in classes, apprising them of this action, permitting them to assert 

timely wage and hour claims in this action and appointment of Plaintiffs and 

their counsel to represent the members of the Collective Actions; 

C. A declaratory judgment that the practices complained of herein are unlawful 

under the FLSA and OMFWSA; 

D. An award of unpaid wages due under the FLSA, the OMFWSA and O.R.C. § 

4113.15, and the Ohio Semi-Monthly Payment Act O.R.C. § 4113.15; 

E. Interest owed and statutory penalty fines/fees in accordance with the Ohio 

Semi-Monthly Payment Act O.R.C. § 4113.15; 

F. An award of liquidated and treble damages as a result of Defendants’ failure 

to pay minimum wages and overtime pursuant to 29 U.S.C. § 216 and O.R.C. 

§§ 4111.01, et seq.; 

G. An award of prejudgment and post judgment interest; 

H. An award of compensatory damages; 

I. An award of treble damages under antitrust laws; 

J. An award of costs and expenses of this action together with reasonable 

attorneys’ fees and expert fees; 

K. Injunctive relief barring Defendants in active concert or participation from 

using, promulgating, and enforcing the unlawful tenant system; exacting 

illegal “rent” and damages; and engaging in further anticompetitive 

conspiracies; and 

L. Such other legal and equitable relief as this Court deems appropriate. 

Respectfully submitted, 

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 /s/ Steven C. Babin, Jr. 

Steven C. Babin, Jr. (0093584) 

Lance Chapin (0069473) 

 Chapin Legal Group, LLC 

 580 South High Street, Suite 330 

 Columbus, Ohio 43215 

 Telephone: 614.221.9100 

 Facsimile: 614.221.9272 

 E-mail: steven.babin@chapinlegal.com

 lance.chapin@chapinlegal.com

 

 Attorneys for Plaintiffs 

 Jane Doe 1, et al.

JURY TRIAL DEMAND

 Plaintiffs demand trial by jury on all issues. 

 /s/ Steven C. Babin, Jr. 

Steven C. Babin, Jr. (0093584) 

       Chapin Legal Group, LLC

 Attorney for Plaintiffs 

 Jane Doe 1, et al.

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