Professional Documents
Culture Documents
Lawsuit Vs Jimmie Allen & Others
Lawsuit Vs Jimmie Allen & Others
JANE DOE, )
)
Plaintiff, ) No.
)
v. ) JURY TRIAL DEMANDED
)
WILLIAMS BOWERS MANAGEMENT, )
LLC D/B/A WIDE OPEN MUSIC, )
ASH BOWERS, JIMMIE ALLEN, and )
JOHN DOES 1-100 )
)
Defendants. )
VERIFIED COMPLAINT
Plaintiff Jane Doe (“Plaintiff”) by and through her attorneys, for her Verified Complaint,
INTRODUCTION
1. Just out of college graduating magna cumme laude, Plaintiff landed her first day-
to-day artist management position with Wide Open Music (“WOM”), an artist management
company based in Nashville, Tennessee. WOM and its founder Ash Bowers (“Bowers”)
promised to guide and teach Plaintiff about the music and talent management industries, the role
2. WOM assigned Plaintiff as the Day-to-Day Manager for WOM client Jimmie
Allen (“Allen”), a multi-platinum recording artist and songwriter in country music. Bowers was
Allen’s Principal Manager. Plaintiff understood this assignment was the chance of a lifetime.
3. At the time WOM assigned Plaintiff to work with Allen, Bowers warned Plaintiff
that Allen was known to push inappropriate sexual boundaries. Bowers advised Plaintiff that
Allen was promiscuous but “harmless,” implying that it was inevitable that Allen would make
4. But it was not normal. Rather, WOM knew that Allen was dangerous, and
assigned Plaintiff to be his Day-to-Day Manager anyway. WOM did not adequately warn or
prepare Plaintiff for, or protect her from, the extreme sexual harassment, abuse, grooming, and
performances, when Plaintiff was representing WOM as Jimmie Allen’s manager, Allen sexually
harassed Plaintiff openly and publicly by making comments about her status as a single female,
her innocence, and how hot she looked. He did so from the stage, in front of the production crew
and public audiences. During debriefings after performances, Allen would ask Plaintiff personal
6. Plaintiff lacked knowledge and experience regarding sex and workplace behavior
but relied on WOM’s and Bowers’ direction that this was normal and harmless behavior.
8. In March 2021, after filming an American Idol episode in which Allen appeared,
Allen sexually assaulted Plaintiff, while she was incapacitated and incapable of giving consent.
9. Despite Plaintiff’s subsequent attempts to decline Allen’s sexual abuse and her
outward expressions of extreme discomfort, Allen manipulated and used his power over
Plaintiff’s job to sexually harass and abuse her over the course of the next 18 months.
10. Bowers and WOM were aware of Allen’s history and that it was likely happening
to Plaintiff. Plaintiff expressed that she was uncomfortable working with Allen, and at least one
other third party reported Allen’s inappropriate behavior with Plaintiff to WOM and Bowers.
sexually abusing Plaintiff. Instead, it was made clear to Plaintiff that she would lose her job if
she complained.
11. By October 2022, Plaintiff was severely depressed and anxious and had
considered suicide as a result of Allen’s conduct. On October 4, 2022, Plaintiff sat down with
Bowers, her boss, disclosed that she had been raped and sexually abused, told him she could not
put up with Allen’s abuse any longer, and asked that she be reassigned.
12. Rather than reassign her, WOM placed Plaintiff on leave and then fired her on
13. Plaintiff brings this lawsuit for violations of 15 U.S.C. § 1591 (sex trafficking)
against Jimmie Allen and Count II for violations of 15 U.S.C. § 1591, 1595 (participation in a
venture engaged in sex trafficking) against WOM and Bowers, as well as claims under common
law.
this action arises under the laws of the United States. This Court also has supplemental
15. Venue is proper in this District under 28 U.S.C. § 1391 (a)–(d) because, inter alia,
substantial parts of the events or omissions giving rise to the claim occurred in the District.
PARTIES
16. Plaintiff is a citizen of the United States and resident of Williamson County,
Tennessee.
17. Defendant Jimmie Allen is a citizen of the United States and resident of Tampa,
Florida.
Tennessee.
19. Defendant Williams Bowers Management, LLC d/b/a Wide Open Music is a
Tennessee corporation with its principal place of business located in Nashville, Tennessee.
FACTS
A. WOM held Plaintiff out as an employee and controlled her daily work
activities.
20. In February 2020, Plaintiff was hired as a Day-to-Day Artist Manager at WOM.
While WOM paid Plaintiff as an independent contractor, WOM otherwise treated her like an
employee. WOM held Plaintiff out as an employee to the artists that WOM represented and held
21. WOM had the right to control the manner and means by which Plaintiff’s role as
an Artist Manager was accomplished, and she discussed how she would do so and received
22. As a 2019 college graduate, Plaintiff’s hiring by WOM in 2020 reflected her
promise as an up-and-coming artist manager but also reflected that she did not have the
experience to be an independent manager without the oversight of Bowers and WOM. Bowers
checked in with her daily to discuss the manner and methods by which she was to execute her
responsibilities.
23. WOM assigned Plaintiff as the Day-to Day Manager for music artist Jimmie
Allen, with whom WOM had a contract. Bowers was assigned as Allen’s Principal Manager and
24. Plaintiff worked full-time for WOM, attending events where Allen had to appear
or perform as WOM’s representative and Day-to-Day Manager. WOM required that Plaintiff
25. WOM had the right to assign Plaintiff additional projects. Plaintiff did not have
discretion over when and how long to work; she was required to support WOM’s artist Jimmie
Allen at all of his events and appearances and be on call at all times. The work in which Plaintiff
26. Plaintiff timely filed a Charge of Discrimination against WOM on March 28,
2023. She will update this lawsuit upon receipt of a Right to Sue letter to assert claims against
WOM under Title VII and the Tennessee Human Rights Act.
28. In advance, Bowers warned Plaintiff that Allen could be challenging by pushing
inappropriate boundaries. Bowers advised Plaintiff that Allen was promiscuous but “harmless,”
implying that it was inevitable that Allen would make sexual advances on Plaintiff. Bowers told
29. Plaintiff was also told that another WOM employee, formerly assigned as Jimmie
Allen’s Day-to-Day Manager, had been fired from Wide Open Music after she defended another
woman who was the target of Jimmie Allen’s sexual advances. (WOM later rehired her under a
30. Bowers and other WOM employees treated Jimmie Allen’s sexual harassment as
normal.
performances, when Plaintiff was representing WOM as Allen’s manager, Allen sexually
harassed Plaintiff openly and publicly by making comments about her status as a single female,
her innocence, and how hot she looked. He did so from the stage, in front of the production crew
32. During debriefings after performances, Allen would ask Plaintiff personal sexual
questions, including whether she was a virgin. Plaintiff lacked knowledge and experience
regarding sex and workplace behavior but relied on Bowers’ direction that this was normal and
harmless behavior.
33. Over time, Allen progressed to touching and hugging Plaintiff, even though
Plaintiff was uncomfortable. Despite her discomfort, Bowers often expressed his gratitude for
Plaintiff’s efforts and stated she was the cause of removing a great deal of pressure from him and
WOM because she was able to handle Allen. Therefore, she continued to try to handle Allen’s
34. In March 2021, after filming an American Idol episode in which Allen appeared,
Allen, Plaintiff, and industry executives attended a dinner. While she only drank a couple of
glasses of white wine, Plaintiff does not remember anything after dinner that evening—she lost
consciousness and awoke naked in her hotel room several hours later, with Jimmie Allen
insisting she take Plan B as soon as possible. Plan B is emergency contraceptive that helps
35. Disoriented and confused, Plaintiff was bleeding vaginally. Plaintiff felt mortified
and humiliated. She realized she had lost her virginity through no choice of her own and felt she
36. Notwithstanding the disoriented and injured state Plaintiff was in, Allen insisted
that Plaintiff go with him to the nearest drugstore to purchase Plan B. After rushing to the
drugstore and returning to the hotel, Allen opened the pack of Plan B and supervised Plaintiff
while she took the medication. Afterwards, Plaintiff started to leave. On the way out, Allen
grabbed her and forcibly kissed her goodbye, whispering, “You’re mine now.” Plaintiff felt
completely numb.
37. Plaintiff was terrified that if she reported Allen to Bowers, she would be
Plaintiff’s WOM-issued computer. Shocked, she immediately closed the browser and shut the
laptop.
39. However, Allen’s hair and makeup assistant witnessed the incident and reported it
40. Allen ensured the hair and makeup assistant was fired for being a “snitch.”
41. In May 2021, Allen told Plaintiff that his uncle said to him“I don’t know why
you’re not hitting that every day,” referring to Plaintiff. Plaintiff reported this statement to
Bowers.
42. Despite the fact that Allen’s behavior was reported to Bowers by Allen’s hair and
makeup assistant and by Plaintiff, neither WOM nor Bowers took appropriate or sufficient action
harassment, neither WOM nor Mr. Bowers investigated to determine whether and to what extent
including grabbing her breasts or buttocks from behind or harassing her to engage in sexual
conduct. Jimmie Allen put his hands down her pants in public. When she tried to push him
44. When Plaintiff drove Allen to and from events, he sexually abused her at red
lights, in green rooms, on airplanes, and in other places she was required to be to support him at
events. He raped her in private while choking her. He videotaped multiple sexual encounters in
45. Plaintiff expressed in words and actions that Jimmie Allen’s conduct was
unwelcome, including pushing him away, sitting where he could not reach her, telling him she
46. However, Allen made clear that Plaintiff’s job was dependent on her staying
47. On one occasion in July 2021, while Plaintiff was sitting in her WOM office,
Plaintiff’s distress was noticeably visible. Thus, Bowers and another WOM executive met with
Plaintiff and asked if anything was wrong. Plaintiff said that Allen was difficult to work with.
48. Plaintiff’s display of distress should have come as no surprise to WOM and
Bowers given that they knew of Allen’s pattern of sexual harassing women generally and
Plaintiff specifically. Nonetheless, neither WOM nor Mr. Bowers investigated to determine
49. Instead, they told Plaintiff to limit her travel with Allen to essential trips, knowing
this instruction was meaningless given the role of a day-to-day artist manager is to act as a
50. Moreover, Bowers and WOM had made clear that Plaintiff was to tolerate Allen’s
misconduct. Given that WOM had fired Allen’s prior Day-to-Day Manager for complaining,
Plaintiff understood that her job was dependent on tolerating Allen’s misconduct. However, no
person should have to tolerate sexual harassment and sexual assault to maintain their job.
51. On or around February 15, 2022, while in Honolulu, Hawaii, for WOM, Plaintiff
almost collapsed on set (where she was representing Allen for WOM) and was rushed to the
emergency room. Plaintiff spoke to the ER doctor and told him about the vicious cycle with
Allen. The doctor advised Plaintiff to “run” and get far away from Allen, documenting the
52. On or about March 6, 2022, Plaintiff sat down with her boss, Bowers, and began
53. Bowers told Plaintiff that it would be best if she confronted Allen 1-on-1 and that
Allen “would suffer” if she were to leave her job. Notwithstanding their knowledge of Allen’s
history of sexual harassment, neither WOM nor Bowers investigated to determine whether and to
what extent Plaintiff was being harmed. Nor did they take any action to protect Plaintiff.
54. Allen continued to sexually harass and assault Plaintiff. Throughout, Plaintiff
became increasingly depressed and anxious. She felt she was on the verge of a nervous
breakdown and considered committing suicide. She was pushed to her breaking point.
55. On October 4, 2022, Plaintiff sat down again with Bowers, told him she could not
put up with Allen’s abuse any longer, and asked that she be reassigned.
56. Bowers scheduled a follow-up meeting with Plaintiff for October 7, 2022. During
disclosed the details of Allen’s abuse. During this discussion, Bowers stated, “I can’t hear any
57. Later that day, on October 7, 2022, Bowers texted Plaintiff and told her that
WOM was placing her on leave, she should not come into the office, and he had to think about
his options.
58. On or about October 17, 2022, Bowers texted Plaintiff stating, “[W]e are still
unwinding things with Jimmie. Until that process is complete- we need you to continue to
59. On or about October 24, 2022, Bowers sent Plaintiff a text message, scheduling a
60. On October 26, 2022, at the in-office meeting, WOM terminated Plaintiff.
CAUSES OF ACTION
COUNT I
VIOLATION OF 18 U.S.C. § 1591, 1595 (SEX TRAFFICKING)
(VERSUS JIMMIE ALLEN)
61. Plaintiff incorporates by reference all prior paragraphs as if set forth in full herein.
interstate or foreign commerce, recruited, enticed, or solicited Plaintiff knowing that means of
force, threats of force, fraud, or coercion (or a combination thereof) would be used to cause
Plaintiff to engage in any sex act on account of which anything of value would be given to or
including through travel to states outside Tennessee with Plaintiff or at which he met Plaintiff for
official events and during which he sexually assaulted and abused Plaintiff.
limited to by requiring her to perform her regular job activities (such as accompanying him to
65. Allen knew he would use fraud, physical force, or coercion with Plaintiff for a
sexual encounter.
66. Allen was well aware that the role as his Manager, or the chance to work for him
directly, was of significant commercial value to Plaintiff. He used this value, or the prospective
use of his influence on Plaintiff’s behalf, to recruit and entice Plaintiff to private locations,
including his hotel room, home, car, and event locations, where he would perform sex acts.
67. By virtue of these violations of 18 U.S.C. § 1591, 1595, Jimmie Allen is liable to
Plaintiff for the damages she sustained and reasonable attorneys’ fees.
COUNT II
VIOLATION OF 18 U.S.C. § 1591, 1595
(PARTICIPATION IN A VENTURE ENGAGED IN SEX TRAFFICKING)
(AGAINST WOM AND BOWERS)
68. Plaintiff incorporates by reference all preceding paragraphs, as if fully set forth
herein.
69. 18 U.S.C. § 1595 provides in pertinent part that an individual who is a victim of
sex trafficking under 18 U.S.C. § 1591 may bring a civil action against “any person whoever
which that person knew or should have known has engaged in an act in violation of this chapter.”
70. First, as set forth above and in Count I, Jimmie Allen engaged in acts in violation
of 18 U.S.C. § 1591.
71. Second, as set forth above, each of WOM and Bowers knew or should have
known that Allen was engaging in acts that constitute sex trafficking in violation of 18 U.S.C. §
72. Each of WOM and Bowers benefitted financially from their participation in the
cover-up and venture because it ensured that Allen continued to perform, ensuring that WOM
and Bowers continued to make money off Allen’s stature and performances.
73. 18 U.S.C. § 1595 does not require that the benefactors of the venture knew or
should have known of the specific victim that is bringing the suit. Rather, it is sufficient that the
Defendants knew or should have known that Allen had engaged in acts that constituted a
74. By virtue of these violations of 18 U.S.C. § 1591, 1595, Defendants are liable to
Plaintiff for the damages she sustained and reasonable attorneys’ fees.
COUNT III
BATTERY
(AGAINST JIMMIE ALLEN)
75. Plaintiff incorporates the preceding paragraphs as if fully set forth herein.
76. Allen intended to commit an act of unwanted contact and/or caused imminent
apprehension of such an act against Plaintiff. He did so by, inter alia: (a) isolating Plaintiff
members in closed quarters and dismissing any bystanders; and (b) demanding or threatening
sexual contact.
77. Allen did commit unwanted contact with Plaintiff’s person or property in a
harmful or offensive manner, including, but not limited to, causing sexual contact between Allen
and Plaintiff.
78. Allen’s battery of Plaintiff caused harm, including physical, mental, and/or
emotional harm.
Plaintiff. He did so by, inter alia: (a) isolating Plaintiff in closed quarters and dismissing any
bystanders; (b) demanding or threatening sexual contact; (c) cornering, blocking, or otherwise
using his heft to cause Plaintiff to fear that Allen had the ability to carry out his physical threats;
and (d) threatening harm to the career and reputation of Plaintiff if she did not participate in such
conduct.
82. Allen’s actions did, in fact, cause Plaintiff to fear imminent harmful or offensive
contact by Allen.
COUNT V
FALSE IMPRISONMENT
(AGAINST JIMMIE ALLEN)
84. Plaintiff incorporates the preceding paragraphs as if fully set forth herein.
85. Without her consent, Plaintiff was willfully detained by Allen while he battered,
86. Allen willfully detained Plaintiff through physical force and/or through
intimidation. In many instances, Allen used such intimidation that Plaintiff stopped resisting
89. WOM and Bowers owed Plaintiff a duty to use due care to ensure her safety and
freedom from sexual harassment or abuse while interacting with their clients.
90. Plaintiff’s acceptance of WOM’s offer to join its artist management team,
including seeking out guidance and direction from WOM and Bowers in the course of his
fiduciary relationship between Plaintiff and Bowers, and between Plaintiff and WOM, resulting
91. WOM and Bowers’ failure to adequately supervise its client Jimmie Allen or
Allen’s interactions with Plaintiff, especially after WOM and Bowers knew or should have
known of complaints regarding Allen’s sexual harassment and abuse to other WOM employees
and third parties, as well as Plaintiff, was so reckless as to demonstrate a substantial lack of
92. WOM and Bowers’ conduct demonstrated a willful disregard for precautions to
93. WOM and Bowers’ conduct, as described above, demonstrated a willful disregard
94. WOM and Bowers breached duties owed to Plaintiff and were grossly negligent
when they conducted themselves as described above, said acts having been committed with
reckless disregard for Plaintiff’s health, safety, constitutional and/or statutory rights, and with a
COUNT VII
NEGLIGENCE
(AGAINST WOM AND BOWERS)
96. Plaintiff incorporates by reference all prior paragraphs as if set forth in full herein.
97. WOM and Bowers owed Plaintiff a duty to use due care to ensure her safety and
freedom from sexual harassment or abuse while interacting with WOM’s clients.
98. WOM and Bowers’ negligence in supervising Allen and Allen’s interactions with
Plaintiff, especially after WOM and Bowers knew or should have known of complaints regarding
his sexual harassment and abuse, was a substantial factor in causing harm to Plaintiff.
99. WOM and Bowers’ conduct demonstrated a negligent disregard for precautions to
100. WOM and Bowers’ conduct demonstrated a negligent disregard for substantial
risks to Plaintiff.
101. WOM and Bowers breached duties owed to Plaintiff and were negligent when
they conducted themselves as described above, said acts having been committed with disregard
for Plaintiff’s health, safety, constitutional and/or statutory rights, and with a substantial lack of
COUNT VIII
NEGLIGENT FAILURE TO WARN, TRAIN, OR EDUCATE
(AGAINST WOM AND BOWERS)
103. Plaintiff incorporates by reference all prior paragraphs as if set forth in full herein.
104. WOM and Bowers owed Plaintiff a duty to take reasonable protective measures to
protect her from the risk of sexual harassment and abuse by Allen by properly warning, training,
105. WOM and Bowers breached their duty to take reasonable protective measures to
protect Plaintiff from the risk of sexual harassment and abuse by Allen, such as the failure to
properly warn, train or educate Plaintiff about how to avoid such a particular risk that Allen
COUNT IX
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(AGAINST WOM, BOWERS, AND ALLEN)
107. Plaintiff incorporates by reference all prior paragraphs as if set forth in full herein.
108. WOM’s, Bower’s, and Allen’s extreme and outrageous conduct intentionally or
109. WOM’s, Bower’s, and Allen’s outrageous conduct was not the type of ordinary
rude or obnoxious behavior that women should be expected to weather. Rather, WOM’s,
110. WOM, Bowers, and Allen acted with intent or recklessness, knowing that Plaintiff
111. Indeed, they used this distress to subdue and explicitly or implicitly threaten
Plaintiff to remain silent or lose her job and to prevent her from complaining or suing based on
their actions. They did so with deliberate disregard as to the high possibility that severe
112. WOM, Bowers, and Allen’s conduct caused suffering for Plaintiff at levels that no
114. WOM, Bowers, and Allen’s conduct negligently caused emotional distress to
Plaintiff.
115. Defendants could reasonably foresee that their actions would have caused
116. WOM, Bowers, and Allen’s conduct caused suffering for Plaintiff at levels that no
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment for Plaintiff
and against Defendants, award her compensatory, incidental, consequential, and punitive
damages, award her reasonable attorneys’ fees and costs, and grant such other and further relief
I, Jane Doe, declare under penalty of perjury and certify that the statements and
allegations outlined in this Complaint are true and correct, except as to matters therein stated to
be on information and belief and as to such matters, the undersigned certifies as aforesaid that I
verily believe the same to be true.
Jane Doe
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
John Spragens, Spragens Law PLC, 311 22nd Ave. N. Nashville, TN 37203,
(615) 983-8900;
Elizabeth Fegan, Fegan Scott LLC, 150 S. Wacker Dr., 24th Floor,
Chicago, IL 60606 (312) 741-1019
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government ✖ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
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