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 LISA-ATHENA S. 

ABU HANTASH IN SUPPORT OF 

PLAINTIFFS’ MOTION FOR A 

DEFAULT JUDGMENT, SUMMARY 

JUDGMENT AND OTHER RELIEF 

STATE OF _________________ ) 

 ) ss. 

COUNTY OF _______________ ) 

 LISA-ATHENA S. ABU HANTASH, having been duly sworn, deposes and says under 

penalty of perjury: 

1. I am the named Plaintiff and mother and natural guardian for Jordan-Annettee 

Jazzmin Richardson 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. 

3. I incorporate by reference the allegations contained in the complaint verified by 

your affirmant and filed with this Court on April 30, 2007. 

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The 2005 Management Agreement And 2006 Management Agreement

4. On or about April 22, 2005, my daughter, Jordan Richardson, entered into a 

model management contract (“2005 Management Agreement”) with Defendant V Model 

Management New York, Inc. (“V Management”). Ex. A. 

5. I indicated my consent to my daughter entering into the contract by signing the 

2005 Management Agreement in my capacity as mother and legal guardian of Jordan. Id. at 6. 

6. By executing the 2005 Management Agreement, I was not agreeing to perform 

and/or assume any obligations. In fact, the 2005 Management Agreement did not require me to 

perform any act or even ensure that my daughter performs in accordance with the terms of the 

agreement. Ex. A. 

7. In or about June 2006, Defendant V Management and/or Defendant VNY Model 

Management, LLC (“VNY”) represented to me that a new agreement would have to be executed 

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

8. Defendant V Management further represented to me that it could not pay and 

would not pay my daughter for the work she performed pursuant to the 2005 Management 

Agreement unless and until a new agreement was executed with Defendant VNY. I thought this 

was extremely odd because I could not understand why a company which changed its name 

would be unable to pay my daughter for services she had already rendered. However, as I have 

three (3) children to support, I felt obligated to enter into a new agreement so that my daughter 

could get paid for her past and future modeling services. 

9. Subsequently, I discovered that Defendants V Management and/or VNY 

continued to pay other models pursuant to their management agreements with Defendant V 

Management — even though they did not execute new agreements with Defendant VNY. 

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10. Notwithstanding and based on Defendant V Management and/or Defendant 

VNY’s representations to me and my daughter, I requested that Defendant VNY forward to me a 

new agreement to review. 

11. On or about June 19, 2006, I received an agreement dated June 19, 2006 between 

Defendant VNY and Plaintiff Jordan Richardson, Inc. (“2006 Management Agreement”). At the 

time that I received the 2006 Management Agreement, Defendant VNY had not yet executed the 

2006 Management Agreement. 

12. I reviewed the 2006 Agreement and made hand-written changes directly on the 

document. One of the provisions that I noticed was missing from the agreement was Jordan 

Richardson, Inc.’s right to terminate the 2006 Management Agreement. Ex. B. 

13. This clause was also missing in my daughter’s 2005 Management Agreement and 

we found it to be patently unfair. Obviously, if my daughter (or my daughter’s company) was 

required to execute a new contract (which turned out to be unnecessary), we did not want to be 

bound to any agreement in perpetuity if we were unhappy. 

14. Therefore, I inserted the following provision onto the signature page of the 

proposed contract: 

“Jordan Richardson, Inc. has the right to terminate the agreement with VNY 

Model Mgt, LLC with 30 days prior notification of the conclusion of said 

Agreement” (“Termination Provision”). 

See Ex. B at 6. 

15. After inserting the provision into the agreement and signing the 2006 

Management Agreement in my capacity as Jordan’s mother and legal guardian, I faxed the 2006 

Management Agreement to Defendant VNY for its signature on or about July 6, 2006. 

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16. Rather than signing the 2006 Management Agreement, Defendants objected to the 

language of the Termination Provision. 

17. On or about July 17, 2006, I modified the language of the Termination Provision 

to read as follows: 

“Jordan Richardson or representative has the right to cancel the contract with a 

written notice 30 days prior to the expiration of the contract” (“Modified 

Termination Provision”). 

See Ex. C. 

18. Again, I signed the 2006 Management Agreement in my capacity as Jordan’s 

mother and legal guardian. 

19. At this point, my daughter and/or Jordan Richardson, Inc. had not signed the 2006 

Management Agreement. To this day, Jordan Richardson and/or an authorized representative of 

Jordan Richardson, Inc. have not signed the 2006 Management Agreement. 

20. Subsequently, I sent the 2006 Management Agreement containing the Modified 

Termination Provision to Defendants VNY for its acceptance and execution. 

21. However, Defendant VNY did not provide me with an executed copy of the 2006 

Management Agreement or respond to my revisions. It was my belief that unless and until a 

fully executed agreement was signed and exchanged, the parties (in this instance my daughter 

and Defendant V Model Management) were working under the terms of the 2005 Management 

Agreement. 

22. In or about October 2006, I realized that Defendant VNY did not provide me with 

a copy of the executed 2006 Management Agreement — nor did Defendant VNY communicate 

that it had accepted the terms of the 2006 Management Agreement, as modified. 

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23. Thereafter, from October 2006 to February 16, 2007, I and my mother, Rachelle 

Saunders (Jordan’s grandmother), contacted Defendant VNY several times requesting it provide 

me with an executed copy of the 2006 Management Agreement. 

24. On or about February 12, 2007, Defendant VNY informed me that I would 

receive a copy of the executed 2006 Management Agreement no later than February 16, 2007. 

25. However, I did not receive an executed copy of the 2006 Management Agreement 

by February 16, 2007. 

26. In a letter dated February 16, 2007, I informed Defendant VNY that because it 

had failed to provide me with a copy of the 2006 Management Agreement, the 2006 

Management Agreement was rejected. Ex. D. 

27. Specifically, I stated the following: 

“I have made several repeated attempts to get a copy of the signed [2006 

Management Agreement] (dated June 2006 and expires June 2008) . . . Since 

these attempts have been unsuccessful, the only valid contract I have with you is 

the [2005 Management Agreement] dated 22 April 2005 which expires 22 April 

2007. 

 Know then that at the 22 April 2007 contract expiration date, I will not renew 

Jordan Richardson’s contract with your agency. Do not schedule any jobs for her 

beyond this date.” 

Ex. D. 

28. It is important to note that the correspondence dated February 16, 2007 was sent 

via Federal Express on February 17, 2007. A true and accurate copy of the Federal Express 

receipt is annexed hereto as Exhibit E. 

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29. According to the Federal Express web site, the letter rejecting the 2006 

Management Agreement was accepted by Defendants’ attorney, Natalia Nastaskin, Esq., on 

February 20, 2007 at 2:11 p.m. A true and accurate copy of the Federal Express proof of 

delivery with signature is annexed hereto as Exhibit F. 

30. More than a week after I sent this correspondence out rejecting the 2006 

Management Agreement and via correspondence dated February 27, 2007, Ms. Nastaskin mailed 

an executed copy of the signature page of the 2006 Management Agreement containing the 

Modified Termination Provision. Ex. G. 

31. In that same correspondence, Ms. Nastaskin informed Jordan that the 2006 

Management Agreement was in “full force and effect and may not be terminated, except in 

accordance with the terms thereof.” Id,

32. In addition and via correspondence dated March 2, 2007, Ms. Nastaskin reiterated 

Defendant VNY’s position that the 2006 Management Agreement is in full force and effect. Ex. 

H. 

33. To this day, I cannot understand how she could make such a ludicrous claim 

because 10 days earlier we had rejected the 2006 Management Agreement. Our rejection was 

sent on February 17, 2007 and received by the Defendants on February 20, 2007. See Ex. D and 

F. Defendants did not respond with an “acceptance” until February 27, 2007. Ex. G. 

34. Defendants’ assertion that the 2005 Management Agreement and/or 2006 

Management Agreement are enforceable with respect to myself, my daughter and/or my 

daughter’s company is making it extremely difficult to find another management company who 

is willing to represent Jordan in her professional career. 

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35. Without the Court’s assistance, I believe my daughter’s career will be 

jeopardized. My daughter has a lot of potential, but she must be free from the grip of the 

Defendants in order to go on with her career. Money cannot adequately compensate us at this 

juncture. 

36. It is therefore respectfully requested the Court grant our application to 

permanently enjoin the Defendants from asserting to any one that my daughter is represented by 

V Model Management and/or VNY Model Management. 

Improper Deductions and Expenses

37. Generally when Jordan performed a modeling assignment, Defendant VNY would 

deduct its management fee and other expenses advanced to Jordan. 

38. However, many of the invoices setting forth the deducted advancements and 

expenses did not accurately reflect the amount for those advancements and expenses. 

39. According to my accountant, Jordan received a total of $416,000.00 in payments 

from Defendants. However, Jordan was given a Form 1099 for $405,713.79. I would like to 

know how there can be a $10,286.21 discrepancy. The last thing my daughter needs is a notice 

from the Internal Revenue Service requesting an audit. 

40. In addition, my accountant informs me that Defendants deducted “expenses” in 

excess of $400,000.00. If I were to add that number to what my daughter received (according to 

her 1099), the net total would be $805,713.79. That means the Defendants’ “cut” was equal to 

49.6% of the net total paid to Jordan. Something is definitely wrong. 

41. As such, I have a good-faith basis to believe that Defendants have made improper 

deductions for expenses and advancements. 

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