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Re: [redacted] Complaint (No [redacted] )Dear [redacted] :As noted in my email dated July 13, this Firm represents T.H.EArtist Agency ("T.H.E.") with regard to the various complaints lodged against it by [redacted] The purpose of this letter is to respond to [redacted] 's most recent complaint with the Revdex.com[redacted] has lodged serious complaints against T.H.Ein various agencies and now with the Revdex.com, each of which has escalated in terms of allegations and toneT.H.Etakes these complaints and allegations seriously - as it does its reputationT.H.Eretained counsel to respond to [redacted] 's most recent complaint because it is troubled by the number of untrue statements included in [redacted] 's complaintI have written to [redacted] directly on behalf of T.H.E., to provide her with all the information T.H.Ehas provided to the various agencies with which she has complained (along with the Revdex.com)T.H.Eis optimistic its transparency and willingness to share this information will address [redacted] 's concerns.Before addressing some of the specifics of [redacted] 's June complaint, I would like to take this opportunity to provide you with some insight into T.H.Eand its businessT.H.Ewas established in by [redacted] , and since that time has put the fashion industry on the map in Washington, D.C., raising the bar for fashion and beauty industry standards hereT.H.Erepresents the top models, hair and maartists, and stylists in the region, and has strong relationships with the region's most prestigious clients (including the major department stores, ad agencies, and photographers)T.H.Eis an institution in the fashion community in the region, and continues to grow and thrive.Because of this history, its position and reputation in the fashion community, and its continued growth, T.H.Ewas perhaps most puzzled by [redacted] 's allegation that it is a scam because "their property was for sale on Zillow.com" and "they never told me either time met with them that they were moving locations." To start, T.H.Edoes not even own the building in which it rents spaceThat said, in full disclosure, T.H.Eis considering relocating its offices (though it has no specific times and no concrete timetable for doing so)But that is simply because T.H.Erequires space better suited to accommodate its business needsFurther, given that there are no immediate plans for the business to locate, it is entirely reasonable that T.H.Ewould not have disclosed to [redacted] that it is considering a potential, hypothetical relocation to an unknown location at an unknown time[redacted] **, Suite [redacted] Washington, DC ***? | T + [redacted] | F + [redacted] Vedder Price P.Cis affiliated with [redacted] ***, which operates in England and Wales, [redacted] ***, which Operates in California, and [redacted] ***., which operates in Singapore,WASHINGTONDC/# [redacted] July 14, Page 2T.H.Ehas emphasized this to [redacted] , and would like to take the opportunity to emphasize it again: After more than thirty years representing the top models and stylists, and working with the most prestigious clients in the area, T.H.Ehas every intention of remaining a thriving and growing modeling agency here.With regard to the other specificallegations in [redacted] 's complaint, it is clear that she and T.H.Ehave very different perspectivesT.H.Edoes not believe that a continued "he said, she said" dialogue will be productive in addressing [redacted] 's concernsIt is important, however, that a number of incorrect statements she has made are Corrected.First, [redacted] shared that she believes T.H.Eis a "scam" because, she alleges, it received a portion of the $she paid to MsJ [redacted] and MsC [redacted] for photography and coaching sessionsT.H.Eabsolutely did not receive any portion of the funds paid by [redacted] to MsJ [redacted] or MsC [redacted] T.H.Erepresents MsJ [redacted] and MsC [redacted] in their work as modelsAny work these individuals do as photographers and coaches is on a freelance basis, and not as part of any business relationship or arrangement with T.H.E [redacted] did not make any payment to T.H.Eand, thus, her demand for a refund from T.H.Eis puzzling.Second, [redacted] shared that she believes T.H.Eis a "scam" because MsE [redacted] allegedly suggested that [redacted] attend a $5,modeling classBut MsE [redacted] in fact told [redacted] that she did not recommend any modeling schools in the areaAnd she most certainly never suggested a $5,modeling classInstead, as described above, T.H.Eactually referred [redacted] to MsC [redacted] for runway coaching, to whom T.H.Eunderstands [redacted] paid a couple hundred dollars, at mostT.H.Eis not a modeling school and is not affiliated with any modeling school, and thus has no economic interest in whether any other potential model enrolls in and pays for a modeling class.Finally, [redacted] contends that she was promised T.H.Ewould represent her as a model, claiming that an emailed statement that T.H.E"would love to get your portfolio online as soon as possible" could Only be interpreted as an express promise of representationWhile at the time of that email, T.H.Ewas optimistic about [redacted] 's potential as a model, a plain reading of that language makes clear that there was no express promise of representationTo the extent [redacted] later claims that another express promise was made, T.H.Eis confident one was not.With regard to a potential resolution of [redacted] 's complaints, as described above, she never paid any money to T.H.EThus, her request for a refund from T.H.Eis baselessTo the extent that a nonmonetary resolution will satisfy [redacted] 's concerns, T.H.Ewould be happy to discuss a potential resolutionT.H.Ewelcomes proposed resolutions from the Revdex.com or [redacted] , but asks that such proposals be transmitted to me directly.T.H.Eregrets that its professional relationship with [redacted] has not unfolded in a manner that either party expected or desiredT.H.Ewishes [redacted] nothing but the best of luck as she pursues modeling and her other passions, whatever they may be.Even if T.H.Ereceived a portion of the fees paid to these Women - which it did not - it is unclear how this would merit the accusation that T.H.Eis a "scam."

Re: *** *** Complaint (No***)Dear *** ***:As noted in my email dated July 13, this Firm represents T.H.EArtist Agency ("T.H.E.") with regard to the various complaints lodged against it by *** ***The purpose of this letter is to respond to *** ***'s most recent complaint with the Revdex.com.*** *** has lodged serious complaints against T.H.Ein various agencies and now with the Revdex.com, each of which has escalated in terms of allegations and toneT.H.Etakes these complaints and allegations seriously - as it does its reputationT.H.Eretained counsel to respond to *** ***'s most recent complaint because it is troubled by the number of untrue statements included in *** ***'s complaintI have written to *** *** directly on behalf of T.H.E., to provide her with all the information T.H.Ehas provided to the various agencies with which she has complained (along with the Revdex.com)T.H.Eis optimistic its transparency and willingness to share this information will address *** ***'s concerns.Before addressing some of the specifics of *** ***'s June complaint, I would like to take this opportunity to provide you with some insight into T.H.Eand its businessT.H.Ewas established in by *** ***, and since that time has put the fashion industry on the map in Washington, D.C., raising the bar for fashion and beauty industry standards hereT.H.Erepresents the top models, hair and maartists, and stylists in the region, and has strong relationships with the region's most prestigious clients (including the major department stores, ad agencies, and photographers)T.H.Eis an institution in the fashion community in the region, and continues to grow and thrive.Because of this history, its position and reputation in the fashion community, and its continued growth, T.H.Ewas perhaps most puzzled by *** ***'s allegation that it is a scam because "their property was for sale on Zillow.com" and "they never told me either time met with them that they were moving locations." To start, T.H.Edoes not even own the building in which it rents spaceThat said, in full disclosure, T.H.Eis considering relocating its offices (though it has no specific times and no concrete timetable for doing so)But that is simply because T.H.Erequires space better suited to accommodate its business needsFurther, given that there are no immediate plans for the business to locate, it is entirely reasonable that T.H.Ewould not have disclosed to *** *** that it is considering a potential, hypothetical relocation to an unknown location at an unknown time.*** *** **, Suite ** ** Washington, DC *** | T + 2*** | F + 2*** Vedder Price P.Cis affiliated with *** *** ***, which operates in England and Wales, *** *** *** ***, which Operates in California, and *** *** *** ***., which operates in Singapore,WASHINGTONDC/#*** *** *** July 14, Page 2T.H.Ehas emphasized this to *** ***, and would like to take the opportunity to emphasize it again: After more than thirty years representing the top models and stylists, and working with the most prestigious clients in the area, T.H.Ehas every intention of remaining a thriving and growing modeling agency here.With regard to the other specificallegations in *** ***'s complaint, it is clear that she and T.H.Ehave very different perspectivesT.H.Edoes not believe that a continued "he said, she said" dialogue will be productive in addressing *** ***'s concernsIt is important, however, that a number of incorrect statements she has made are Corrected.First, *** *** shared that she believes T.H.Eis a "scam" because, she alleges, it received a portion of the $she paid to MsJ*** and MsC*** for photography and coaching sessionsT.H.Eabsolutely did not receive any portion of the funds paid by *** *** to MsJ*** or MsC***T.H.Erepresents MsJ*** and MsC*** in their work as modelsAny work these individuals do as photographers and coaches is on a freelance basis, and not as part of any business relationship or arrangement with T.H.E*** *** did not make any payment to T.H.Eand, thus, her demand for a refund from T.H.Eis puzzling.Second, *** *** shared that she believes T.H.Eis a "scam" because MsE*** allegedly suggested that *** *** attend a $5,modeling classBut MsE*** in fact told *** *** that she did not recommend any modeling schools in the areaAnd she most certainly never suggested a $5,modeling classInstead, as described above, T.H.Eactually referred *** *** to MsC*** for runway coaching, to whom T.H.Eunderstands *** *** paid a couple hundred dollars, at mostT.H.Eis not a modeling school and is not affiliated with any modeling school, and thus has no economic interest in whether any other potential model enrolls in and pays for a modeling class.Finally, *** *** contends that she was promised T.H.Ewould represent her as a model, claiming that an emailed statement that T.H.E"would love to get your portfolio online as soon as possible" could Only be interpreted as an express promise of representationWhile at the time of that email, T.H.Ewas optimistic about *** ***'s potential as a model, a plain reading of that language makes clear that there was no express promise of representationTo the extent *** *** later claims that another express promise was made, T.H.Eis confident one was not.With regard to a potential resolution of *** ***'s complaints, as described above, she never paid any money to T.H.EThus, her request for a refund from T.H.Eis baselessTo the extent that a nonmonetary resolution will satisfy *** ***'s concerns, T.H.Ewould be happy to discuss a potential resolutionT.H.Ewelcomes proposed resolutions from the Revdex.com or *** ***, but asks that such proposals be transmitted to me directly.T.H.Eregrets that its professional relationship with *** *** has not unfolded in a manner that either party expected or desiredT.H.Ewishes *** *** nothing but the best of luck as she pursues modeling and her other passions, whatever they may be.Even if T.H.Ereceived a portion of the fees paid to these Women - which it did not - it is unclear how this would merit the accusation that T.H.Eis a "scam."

June 28, 2017*** *** *** Revdex.com K StNW, 10th Floor Washington DC 20005REF: ID ***Dear *** ***:We are in receipt of your e-mail dated June 27, We also received a phone call on June 27, which Lynda E*** returned, and left a voice mailThese are the only
contacts we have record of receiving.In response to the complaint files by *** ***, we are providing you with all of the documentation we supplied to the Government of the District of Columbia (DC), Office of the Attorney General, Office of Consumer Protection, where *** *** filed a complaint on May 16, We received confirmation that the DC case has been closed, and it appears *** *** is reaching out to your office and other entities now that her complaint to DC was unsuccessful.As an initial matter, it is important to note that *** *** demands a refund of $from T-H-E Artist AgencyHowever, as described below, T-H-E in fact refused to take funds from her and the funds she did pay were paid directly to the testing photographer and runway instructor she engagedFurther, *** *** has alleged she was instructed to take “modeling classes.” To be clear, T-H-E does not offer modeling classes.Further, it is important to share that while T-H-E is in the process of selling the property in which it currently operates, it has no plans to go out of business and is simply moving officesThere is nothing suspect or unusual about this standard business transaction, and it is entirely unclear why *** *** would jump to any assumption regarding our ongoing operations as a result of that transaction.Please find below a summary provided by Torey B*** addressing the complaint made by *** ***Torey is T-H-E’s Marketing Director, and also attends all meetings with the President, *** ***, and any new, potential models:We invited *** *** *** to come into our office for an open call on January 11, 2017, please see exhibit ADuring open call, we spent minutes giving her as much information as we could regarding the industryShe qualified for runway given her size and height, so we had her walk for usOur observation was that she had no prior runway experience and very little experience walking in heels in generalWe suggested in order to go forward she would need to test with a photographer, as she had no previous modeling experience or pictures to show us besides *** digitals.We made *** *** aware that in the follow up email we would include a models essential packet that would be able to explain much more than we could cover in the interview due to time restraintsThis essentials packet would be something she could refer back to whenever needed and could answer many questions about the industry itselfThe following day, I sent her a follow up email, see exhibit B, (the same email we send to all people after an open call, with the exception of a few changes we make to personalize it, exparticular photographers we think would work best with their look)In the email, there is no promise that the model will be represented by the agency, it is just stated that we look forward to working with them and to proceed, they need to have a test shoot doneThis is where we recommend (never require) a photographer and suggest a runway walking class if they are interested in doing runway.*** *** contacted the photographer and runway instructor directly (not through us) and paid them directly as wellTo be clear, T-H-E did not receive any compensation for thisThis business transaction was through *** ***, the photographer and the runway instructorWe give recommendations as a courtesy to protect the models from going online and finding potentially dangerous situationsShortly after our meeting, I set *** *** up with Brian L* ***, a professional photographer, who our agency has worked with in the pastHe had requested models for a free test shoot in exchange for photosWe felt she needed additional clean beauty head shots and something that represents our fashion and lifestyle board, so we recommended she do a test shoot with Misty J*** as wellWhen *** *** received the film back from Misty J***, she claimed the pictures were not good enough due to the weather and demanded another shoot with her, which MsJ*** did for free.After reviewing all of her images from two tests, as an agency, we decided she needed additional experience before being considered for representationWe didn’t feel she was the best fit for our agency in general and I released her via email, see exhibit E.After *** *** was informed that T-H-E would not represent her, her mother then called me at the agency yelling and accusing the agency of being a scam*** *** and her mother's behavior were very inappropriate and unprofessional as *** *** was screaming in the background as well.At that point, I met with *** *** to express my concern for their behavior and in question on how to proceedLynda called and spoke with *** ***'s mother and told her we would be willing to meet with her again, see exhibit C, to discuss what it would take to continue moving forward.During that meeting which took place on April 27, we attempted to address her concerns about making money in the industry and we explained that it takes time and experienceWe explained that we have not made any money and would not make any money from her until she booked a job with usWe recommended other promotional modeling agencies if she needed to make money more quickly to pay back her parentsWe also explained that this could be a great way for her to gain more experience and to get more comfortable modeling, but she did not seem interested

[To assist us in bringing this matter to a close, you must give us a reason why you are rejecting the responseIf no reason is received your complaint will be closed as Answered]
Complaint: ***
I am rejecting this response because:I reject the businesses’ response because:I would like to first address this statement:“Because of this history, its position and reputation in the fashion community, and its continued growth, T.H.Ewas perhaps most puzzled by *** ***'s allegation that it is a scam because "their property was for sale on Zillow.com" and "they never told me either time met with them that they were moving locations."”I only stated that it was a red flag, not that T.H.E is a scam simply because I found their office building was for saleI have no way of knowing who owns the businessAfter all of the unsettling, odd behavior by T.H.E, I only stated that it was concerning that their office building was listed for sale shortly after my first interviewIt is also concerning because Lynda told me multiple times that she was moving out of her “9,square foot home,” but never mentioned anything about moving her business.The next portion of T.H.E’s response I would like to address is:“T.H.Edoes not believe that a continued "he said, she said" dialogue will be productive in addressing *** ***'s concernsIt is important, however, that a number of incorrect statements she has made are CorrectedFinally, *** *** contends that she was promised T.H.Ewould represent her as a model, claiming that an emailed statement that T.H.E"would love to get your portfolio online as soon as possible" could Only be interpreted as an express promise of representationWhile at the time of that email, T.H.Ewas optimistic about *** ***'s potential as a model, a plain reading of that language makes clear that there was no express promise of representationTo the extent *** *** later claims that another express promise was made, T.H.Eis confident one was not.”I do not see how it is a “he said, she said” dialogue, as I have the assurances in writingAdditionally, unlike the lawyer states, I do have another promise that was made by T.H.Efrom the president:“Thank you for your sincere explanation of what you are feelingAs well as you continued commitmentI am looking forward to working with you for runway and printI mentioned to your mother that I am currently moving my residence and when that is complete I would love to meet with youIt's much easier than all the back and forthYou will remain on our boards for development and will be added to the website when I know your ready to be introduced to the clientsKeep practicing!!! You're beautiful and over time I believe you will become strongerOnly you can make that happenLooking forward to seeing you over the next couple weeks.All the best, Lynda” First, why would I need a runway coach so early in the process if there was a possibility they would release me after one shoot? It seems as though that is putting the cart before the horseAdditionally, the email I received after my interview stated: “We would love to get your portfolio online as soon as possibleIn order to do so, you need to pursue testing photographers.” While T.H.Econtends that this is not a promise, to me it was because they did not indicate representation would be based solely on one shoot with an unprofessional photographer in below freezing temperaturesThe packet they sent me clearly states: “Repeat this testing/editing/printing process until you have enough images for a composite card, portfolio and Agency Pad.” T.H.E released me after one shootAdditionally, I do not see how there is another way to interpret this statement from the president: “I am looking forward to working with you for runway and print.” I was never given the opportunity to work with Lynda in either runway nor printAlso, it was stated at the time of the email that T.H.E was optimistic about my potentialNot only had they met me in person, but they took pictures of me at the interview without makeup, and I also sent them pictures without makeupLastly, I would like to address this portion of T.H.E’s response:“T.H.E*** *** did not make any payment to T.H.Eand, thus, her demand for a refund from T.H.Eis puzzlingSecond, *** *** shared that she believes T.H.Eis a "scam" because MsE*** allegedly suggested that *** *** attend a $5,modeling classBut MsE*** in fact told *** *** that she did not recommend any modeling schools in the areaEven if T.H.Ereceived a portion of the fees paid to these Women - which it did not - it is unclear how this would merit the accusation that T.H.Eis a "scam."While I have no proof a portion of the money I spent was given to T.H.E., I do have proof that they only gave my one option for a photographer, and one option for a runway coach in their initial email, and that both of these individuals are models on their websiteIt is very suspicious that the only photographer and runway coach recommended are models on their websiteAs I said, when agencies do not provide models with a list of multiple photographers, this is an indication of a modeling scam (Please refer to my last response for the source)Additionally, I do not believe my request is baselessMy only request was for T.H.Eto follow through with what they stated in the emails so at the very least I could recoup the money I had spentI only requested a refund when I realized I would never earn representationFinally, it is that Lynda never mentioned a $5,modeling school as she mentioned it me as well as my mother
Regards,
*** ***

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