Read the full article by Dan Miller & Peter Warren at

LOS ANGELES—Four adult performers have filed a formal complaint with the Department of Industrial Relations for the State of California against LA Direct Models and its owner Derek Hay, claiming he and his agency violated several laws that govern talent agents.

The performers, identified in the petition as “Jane Does,” allege that Hay and LA Direct “exploited his position of power to abuse his clients both emotionally, financially and sexually.”

Veteran adult industry attorney Allan Gelbard is representing the four Jane Does in the complaint that will go before the State Labor Commissioner’s Board, which oversees, among other things, licensed talent agents.

The Jane Does are seeking to have LA Direct’s agency license revoked, to recover monetary damages and to receive declaratory relief. They are seeking to be let out of their contracts and to recover fees that they allege Hay withheld from them, or that they were forced to pay him but shouldn’t have had to.

Hay told AVN he was not familiar with the complaint because he had not been served with one.

“I have no comment for a Labor Commission complaint that I haven’t seen or have not been served,” Hay said Wednesday night.

One of the Jane Does, performer Charlotte Cross, gave her consent to be identified for this story.

“Adult performers deserve the same respect as any other worker in the state of California,” Cross said in a statement. “When a predatory agency takes advantage of adult performers, they need to be held accountable. I’m saddened it has taken this case over 15 years to reach the Labor Board but I’m incredibly proud of the performers that have decided to speak up, knowing the retaliation they will face. I hope that this will set a precedent for the future and show our industry that with enough tenacity, you can change things for the better. This is our #MeToo movement.”

The complaint alleges that Hay has violated “not less than five sections of the California Talent Agencies Act, as well as numerous other state and federal statutes.” 

According to the filing, the reason the performers are remaining anonymous is because they “each fear a substantial risk of retaliatory physical and/or mental harm; and anonymity is necessary to preserve each Petitioner’s privacy in highly sensitive and personal matters; and, each Petitioner reasonably fears that their professional careers will be damaged by coming forward against a powerful and entrenched industry insider; and each Petitioner may be compelled to admit potentially illegal conduct, thereby risking criminal prosecution.”