Hickey DefaultJudgment Signed
Hickey DefaultJudgment Signed
Hickey DefaultJudgment Signed
17 MAR 14 AM 10:28
KING COUNTY
1 SUPERIOR COURT CLERK
E-FILED
2 CASE NUMBER: 16-2-30379-0 SEA
7 STATE OF WASHINGTON
KING COUNTY SUPERIOR COURT
8
9
17 Defendant.
18 I. JUDGMENT SUMMARY
19 1.1 Judgment Creditor State of Washington
26
26
2 services and solicited consumers for nonexistent jobs in order to obtain sex and nude photos
3 of women. Defendant has no professional talent recruiting experience and has never placed or
7 prospective actresses with job opportunities in the adult film industry; creating talent
8 portfolios for aspiring actresses; and distributing talent portfolios to potential employers in the
9 adult film industry. Defendant has never provided any of these services to consumers.
10 3.5 Defendant promoted his business by creating fake online profiles for a
11 nonexistent talent recruiter named Deja Stwalley. Defendant has used the Deja Stwalley
12 profiles to perpetuate his scam and to solicit women between the ages of 17 and 25 since at
13 least 2006.
14 3.6 Defendant further promoted his business by: soliciting women online through
15 his Deja Stwalley Facebook profile; creating fake consumer profiles on Facebook to endorse
16 New Seattle Talent; providing consumers with phone numbers, email addresses, and mailing
17 addresses designed to legitimize New Seattle Talent; and advertising New Seattle Talents
20 they must apply for an audition with New Seattle Talent to qualify for the jobs advertised.
21 Defendant required prospective actresses to: submit an application form to New Seattle
22 Talent; Skype with Hickey; and provide photographs, sexual history, and a copy of their
24 3.8 Defendant misrepresented to consumers that they must also audition in person
25 with New Seattle Talent to qualify for the jobs advertised. Defendant required prospective
2 shoot with Hickey, who Defendant falsely claimed was New Seattle Talents professional
5 misrepresented to prospective actresses that New Seattle Talent had disseminated talent
6 portfolios to prospective employers and that additional auditions with Hickey would improve
7 job prospects. Defendant never created talent portfolios or disseminated them to prospective
8 employers.
2 described herein.
3 Plaintiff is entitled to a Decree enjoining Defendants from the acts and practices
4 described herein.
6 5.1 The Court enters this judgment in accordance with the Findings of Fact and
8 5.2 Defendant and all successors, assigns, transferees, officers, agents, servants,
9 employees, representatives, and all other persons in active concert or participation with the
10 Defendant is hereby enjoined and permanently restrained in the State of Washington, or from a
13 Washington), from directly or indirectly engaging in any of the following unfair or deceptive
16 service related to talent recruiting, the adult entertainment industry, or helping models or
19 Facebook profiles or other online services to carry out unfair or deceptive business practices.
25 stores photographs, videos, or other personal information he obtained for commercial purposes.
26
5 business practices.
13 5.3 Pursuant to RCW 19.86.080, Defendant shall to return all nude photos obtained
14 through the unfair and deceptive practices addressed to Washington consumers, including but
15 not limited to all physical and electronic copies, backups, or altered versions, or, in the
16 alternative destroy all such photos, including electronic and physical copies, backups, and
17 altered versions.
18 5.4 Pursuant to RCW 19.86.080, Defendant shall remove the nude photos obtained
19 through the unfair and deceptive practices addressed above from the internet and any other
20 public space where Defendant shared, posted, or stored the photos by October 1, 2017.
21 5.5 Pursuant to RCW 19.86.080, Defendant shall relinquish all rights and claims
22 over the nude photos obtained through the unfair and deceptive practices addressed above and
23 any versions of such photos, including all physical and electronic copies, backups, and altered
24 versions.
26 Washington, its costs and reasonable attorneys fees for this action in the amount certain of
5 5.8 All payments made to satisfy this Judgment shall be in the form of a valid check
6 paid to the order of the Attorney GeneralState of Washington. Payment shall be sent to the
9 5.9 Nothing in this Judgment may be construed as to limit or bar any other
10 governmental entity or any consumer in the pursuit of other remedies against Defendant.
12 reasonable notice to Defendant, to access and inspect all business records or documents under
13 the control of Defendant to monitor compliance with the terms of this Judgment.
14 5.11 Pursuant to RCW 19.86.140, any violation of the terms of this Judgment will
15 form the basis for further enforcement proceedings, including, but not limited to, contempt of
16 Court proceedings and forfeiture of the civil penalty of up to Twenty-five Thousand Dollars
18 5.12 The violation of any of the injunctive terms of this Judgment will also constitute
20 5.13 Jurisdiction is retained for the purpose of enabling Plaintiff to apply to the Court
21 for further restitution and for the enforcement of compliance with the terms of this Judgment.
23
24
25 SUPERIOR COURT JUDGE/COMMISSIONER
26
2 ROBERT W. FERGUSON
Attorney General
3
4
s/Andrea Alegrett s/Leilani Fisher
5 ANDREA M. ALEGRETT, WSBA #50236 LEILANI N. FISHER, WSBA #48233
Assistant Attorney General Assistant Attorney General
6 Attorneys for Plaintiff, State of Washington Attorneys for Plaintiff, State of Washington
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Page 9 of 9