Here are a few choice excerpts from the court docs.
Defendants' assurances of privacy and security are reinforced by paid "references"- 14 women hired who are or pose as previous models and (in accordance with a script) provide new 15 recruits with false comfort that the experience is safe and enjoyable, and that the videos have never 16 appeared online or been discovered by anyone in the models' lives.
Defendants increase 28 viewership of the videos by deliberately leaking and disseminating their true identities and personal information-including by sending the videos directly to the models' friends, family members, 2 classmates, employers, and social media contacts. This is similar to a direct-marketing promotional 3 device that makes the videos "go viral" in the models' communities. When the women inevitably 4 learn what Defendants have done with their videos, many complain to Defendants, begging them to 5 remove the videos from the internet. In response, Defendants usually simply ignore any such 6 messages and block the complaining model.
Defendants rush and pressure the woman to 21 sign the documents quickly without reading them and engage in other deceptive, coercive, and 22 threatening behavior to secure their signatures as described below.
However, by the time models have arrived in San Diego and filming is about 14 to begin, they have no choice but to relent and proceed with the shoot. Defendants threaten them 15 with consequences if they do not do so.
[Defendants said the private collector signed a contract 4 that he would not redistribute DVD] Defendants said the 5 DVD was encrypted and could not be copied]; [Defendants 6 said that if the video did somehow end up online, they had ways of taking it down].)
Of the 28 models who testified at trial, Defendants offered alcohol or marijuana to 7 who 4 were underage. This includes McKay, who was 19 years old when Garcia offered her alcohol and 5 marijuana prior to the shoot. Only Jane Does 4 and 16 claim that they were so thoroughly intoxicated that they cannot 7 recall portions of the evening during which the videos were shot. Both show signs of intoxication in 8 their videos. Jane Does I, 8, 15, 17, and 18 testified that they felt moderate symptoms of 9 intoxication. For most of the Plaintiffs, the alcohol or marijuana served to diminish their defenses IO and make them less alert.
Some women testified thatGarcia, Wolfe,and/orPratt became 15 irritable and aggressive when they asked questions about the documents or requested time to read 16 them. Others testified that they were badgered to sign hastily and did not feel that they had the 17 option of asking for more time. The Court finds that Defendants used these tactics to reduce the 18 likelihood that women would read and understand what they were signing. 19 When handing the documents to a model, the Defendants briefly explain the purpose and 20 content of what she is being asked to sign. These representations are false and designed to induce 21 the women to sign without further question. In some instances, Defendants actually tell the model 22 that the documents state that the video will not be released online or in the United States and that 23 her name and privacy will be fully protected. Sometimes, Defendants represent that the documents 24 were "just to prove that [she is] 18," (08/28/19 Trial Tr. 93:9), or to show Defendants were "not 25 forcing [her] to do this," (09/10/19 Trial Tr. 136:14). In other instances, Defendants are vague, 26 saying, "This is just about the basic agreements, everything we spoke about," (09/09/19 Trial Tr. 27 51 :4 - 5), or 'Just kind of a formality." (08/22/19 Trial Tr. 37:16.)