UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

LISA-ATHENA S. ABU HANTASH, in her 

individual capacity and as mother and natural 

guardian of JORDAN-ANNETTEE JAZZMIN 

RICHARDSON, a minor, and JORDAN 

RICHARDSON, INC., a Virginia Corporation, 

 Plaintiffs, -againstV MODEL MANAGEMENT NEW YORK, 

INC. and VNY MODEL MANAGEMENT, 

LLC, 

 Defendants. 

 Docket No.: 07 Civ. 3363 (GBD) (KNF) 

 

AFFIDAVIT OF JORDAN 

RICHARDSON IN SUPPORT OF 

PLAINTIFFS’ MOTION FOR 

SUMMARY JUDGMENT AND 

OTHER RELIEF 

STATE OF _________________ ) 

 ) ss. 

COUNTY OF _______________ ) 

 JORDAN RICHARDSON, having been duly sworn, deposes and says under penalty of 

perjury: 

1. I am the minor Plaintiff and the sole principal of Plaintiff Jordan Richardson, Inc. 

in the above-entitled action. As such, I am fully familiar with the facts and circumstances of the 

within action. 

2. I submit this affidavit in support of my attorneys’ application for, among other 

things, (a) declaratory relief; and, (b) summary judgment pursuant to Rule 56 of the Federal 

Rules of Civil Procedure; or, (c) in the alternative, an Order directing a speedy hearing and 

advancing the within on the trial calendar pursuant to Rule 57. 

2005 Management Agreement and 2006 Management Agreement

3. On or about April 22, 2005, I signed a model management agreement with 

Defendant V Model Management New York, Inc. (“2005 Management Agreement”) to act as my 

manager, representative and advisor for my modeling career. Ex. A. 

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4. At the time that I executed the 2005 Management Agreement, I was only fifteen 

(15) years old. 

5. Because I was under the age of eighteen (18) years old, my mother, Plaintiff LisaAthena S. Abu Hantash, was required to give her consent and allow me to sign the agreement. 

As such, she also executed the 2005 Management Agreement. Ex. A. 

6. In or about June 2006, I was told that I would have to execute another agreement 

because Defendant V Management changed its name to “VNY Model Management, LLC” 

(“VNY”). 

7. After my mother received the proposed agreement (“2006 Management 

Agreement”), she made revisions on certain pages and made notes on others. For instance, on 

page 1 of the proposed agreement my mother wrote in “Jordan Richardson, Inc.?” At the time 

we received this agreement, we were not sure whether I would sign the agreement personally or 

as the member of a newly formed corporation. Ex. B. 

8. In the course of 8 months (June, 2006 through February, 2007), my mother signed 

the 2006 Management Agreement several times because Defendant VNY rejected my mother’s 

revisions in the agreement and requested that she insert revised provisions. 

9. Defendant VNY asserts that the 2006 Management Agreement is fully 

enforceable against Jordan Richardson, Inc. and/or me. However, I never executed the 2006 

Management Agreement in my individual capacity or on behalf of Jordan Richardson, Inc. Ex. 

C. 

10. Furthermore, I am the only person authorized to act on behalf of Jordan 

Richardson, Inc. Specifically, my mother is not authorized to act on behalf of Jordan 

Richardson, Inc. 

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I Disaffirmed Any And All Agreements With Defendants

11. I genuinely do not believe that Defendant V Management and Defendant VNY 

are looking out for my best interests and welfare. One particular instance readily comes to mind. 

12. On or about September 13, 2006, I was physically attacked and choked 

unconscious by another model at a launch party for a magazine in New York City. Because I 

was a minor, I was under the care of the Defendants and Lana Winters, President of Defendants. 

Ms. Winters is also an individual who witnessed the attack. 

13. Even though Ms. Winters witnessed the attack, she did not take any action to 

prevent harm to me. In addition, she did not seek out medical attention or report the incident to 

the New York City Police Department. A few days later, I reported the incident to my mother 

and grandmother who were very upset that the police and/or a medical provider were not called. 

14. As such, I am no longer comfortable having Defendants represent me in my 

professional career. 

15. Thus, on February 17, 2007, my mother sent a letter to the Defendants advising 

that I do not wish to perform any more services for V Model Management and/or VNY Model 

Management. Since February 17 this has been and will always be my position. 

16. Notwithstanding my clear and unequivocal statement that I deem all contracts 

with the Defendants to be terminated, the Defendants insist that I am bound to continue 

performing services for them. 

17. Therefore, in letters dated March 21, 2007 and April 11, 2007, my attorneys 

disaffirmed any and all contracts with Defendants on my behalf and on behalf of Jordan 

Richardson, Inc. Ex. D; Ex. E. 

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18. Defendants still did not get the message. To this day, Defendants continue to 

offer me work. The last time that Defendants offered me work was on May 24, 2007. On each 

and every occasion, I have declined their offers. In addition, I restated my position that any and 

all contracts with Defendants are terminated. Ex. E. 

19. Because the Defendants are taking the position that the 2005 Management 

Agreement and/or 2006 Management Agreement are still enforceable, it is difficult for me to 

find a manager who is willing to represent me in my professional career. 

20. My professional career has picked up momentum in the past couple of years. For 

the year 2006, my gross earnings were in excess of $400,000.00. 

21. I believe that until a final resolution is reached regarding the enforceability of the 

2005 Management Agreement and/or 2006 Management Agreement, I will not be able to pursue 

my modeling career for fear of having others involved in a lawsuit. 

22. In addition, I fear that the period of time it takes to resolve these issues will 

adversely affect my professional career. 

Improper Expenses and Deductions

23. When I performed a modeling assignment, the client who retained my services 

would make direct payment to the Defendants. 

24. Defendants would then withhold a portion of the payment as their “management” 

fee and make other deductions for expenses and advancements. Defendants would then remit the 

balance of the payment to me. However, I have a good faith basis to believe that Defendants 

have made other improper deductions for expenses and advancements. 

25. I am told that out of the $800,000.00 I earned, almost half was taken by the 

Defendants for fees and expenses. I cannot understand how this can happen. I assume that some 

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of the “expenses” are bogus. In addition and in direct contravention to the 2005 Management 

Agreement, Defendants V Management and/or VNY have failed to provide me with a monthly 

itemized listing of all monies advanced by Defendants. Therefore, I am uncertain as to whether 

Defendants had a proper basis for these deductions and/or expenses. Ex. A, Addendum 1.0. 

26. For instance, Defendants arranged an apartment for the models to share in New 

York City and the models pay rent to Defendants. Although Defendants have deducted 

payments for maid and/or cleaning service to the apartment, I do not believe that maid and/or 

cleaning service was ever provided to the apartment. 

27. In addition, Defendants V Management and/or VNY have yet to remit payment to 

me for modeling services previously rendered by me. 

28. As such, I respectfully request that the Court issue an order directing the 

Defendants to account to me for all payments received, deductions taken and payments made to 

me. 

 

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