LOS ANGELES—An attorney for adult performers Lilith Grace and Tess Thompson filed a legal document Thursday that could force 101 Modeling and its controversial founder, Robert Moran, out of the adult industry.

Grace and Thompson—both former 101 models—allege that Moran raped them in hotel rooms while they were intoxicated in separate incidents in 2025. PornCrush reported on both of the alleged assaults, prompting industry-wide backlash toward an agency whose reputation had long been under question.

In a petition submitted to California’s Department of Labor and Standards Enforcement (DLSE), attorney Jim Felton alleges Moran and 101 Modeling committed numerous violations of the Talent Agency Act, the document agents are required to sign before they are granted a license. Specifically, the petition alleges that 101 and Moran violated two provisions of the act.

Section 1700.33 mandates that no talent agency can knowingly send an artist to a place where his or her safety, health, or welfare can be "adversely affected."

In addition, Section 1700.35 stipulates that no talent agency shall knowingly permit persons of bad character—including those who are intoxicated—to be employed in the place of business.

The petition calls for 101 Modeling to “lose its talent agency license” and for Moran to be “barred from acting as a principal of any talent agency licensed by the State of California.”

“The Talent Agency Act has conditions in place to keep agents from putting performers in a position of vulnerability,” Felton, a managing partner at California-based G&B Law, said. “When that happens, the act allows the Department of Labor to step in and terminate an agency’s license to protect performers.”

Reached Friday morning, Grace said she took legal action to help protect other models.

“I’m moving forward with this petition not only because of what Tess and I experienced, but because what happened to us should never happen again,” Grace, 23, told PornCrush. “This is for the girls who come after us—new, innocent, and trusting.”

Thompson echoed those sentiments in a text to PornCrush.

“What happened to Lilith and me was wrong,” Thompson, 22, wrote. “It is not OK, and it is not normal. And to see how it was brushed aside, and almost justified, by the agency … I can only imagine how many more victims there were going to be, and how many there already are. We are doing this for those women.”

A copy of the petition has been sent to Moran, who will have 20 days to respond once he is served. Moran, 46, did not respond to a text message from PornCrush Friday morning seeking comment.

Obtained by PornCrush, the petition to the DLSE outlines in detail the alleged assaults committed by Moran against Grace and Thompson.

The petition says “Moran violated his responsibilities as an agent by putting Grace in an unsafe position” on Feb. 5, 2025. The two spent an afternoon bar-hopping after Grace’s shoot in Las Vegas and then checked into the Flamingo hotel.

"Grace had previously told Moran that she didn’t want to have sex with him, but within seconds of the door shutting behind them, Grace said Moran asked her to take off her clothes because he wanted to see her naked. She said she didn’t think much about the request, as adult stars are accustomed to being nude in front of people they aren’t necessarily going to have sex with.

“The vibe completely changed, and he started touching me,” Grace said. “He wasn’t just making a move sexually; he was making a move romantically, telling me he wanted to give me his car and that he wanted me to be his girlfriend.

“I reminded him how we had established that we weren’t going to fuck, but within 10 minutes, he was on top of me, sticking his fingers in my ass. I’d tell him to stop, and then he would switch to his (penis).

“I kept saying ‘no’ over and over. I don’t know how much more frank I could’ve been. He kept moving my hands away (from my privates) and saying, ‘I’m not going to rape you. I just want to fuck you. Please, just let me fuck you one time so I can say that I fucked you.’

"Grace said she pleaded with Moran not to ejaculate inside of her, telling him she wasn’t on birth control. But he did it anyway before leaving the room to resume drinking downstairs. Grace said Moran came in and out of the room multiple times throughout the night to assault and fondle her and refused to let her leave.

"The following day, Grace would report the matter to the police as rape, but the police did not prosecute, telling Grace it was a “he said – she said” situation. Thereafter, a representative of 101, Danny Frost, told Grace that the agency would re-sign her if the performer retracted her story about being raped by Moran. Frost stated to Grace that the altercation with Moran “wasn’t rape, just stupid drunken stuff.”

"Frost texted Grace, “They want you to post a (retraction). Like maybe say something (like), after talking with Robert, you realize you were both drunk, and when you woke up the next morning, you didn’t remember everything that led up to it. And now you realize it wasn’t rape, just stupid drunken stuff. Make it into your own words.” Grace would not agree to tell a lie. “I can’t do that,” she texted Frost. “That would be flat-out lying. Everything I said was 100 % true.”

The petition states Thompson “was also victim to Moran’s unsafe and unprofessional ways” on Oct. 13, 2025.

The petition reads, "After an afternoon of bar-hopping in Huntington Beach, Thompson and Moran checked into the Pasea Hotel, where Moran continued to feed Thompson shots of vodka. Moran then engaged in non-consensual sex with Thompson, who said she heavily intoxicated, barely conscious and unable to speak or move as Moran penetrated her from behind.

“The best way to describe it is that it felt like I was dreaming,” Thompson said. “I knew it was happening, but I couldn’t say anything or move or do anything. It was, like, an out-of-body experience. I felt all this pressure on my knee, and I wanted to squirm, but I couldn’t.”

"Thompson (passed) out and later awoke to discover Moran standing naked beside the bed. When she asked him what had happened, Thompson said the agent began laughing hysterically. “Just suck my dick,” she said. Moran told her. “Just suck my dick.”

"Still somewhat disoriented, Thompson refused and then walked onto the balcony to collect her thoughts. She noticed that her left knee was bruised and swollen, presumably, she said, from it being pinned against the wooden baseboard of the hotel bed. Thompson went back inside and confronted Moran again about what had unfolded. She said he confirmed that they had intercourse and then told Thompson he ejaculated inside of her.

“He said, ‘I came inside you, and you’re going to get pregnant,’” Thompson said. “He told me he wanted me to have his babies.” When Thompson expressed anger and asked Moran why he would do such a thing without her consent, she said he laughed once again. “I’m a monster!” she said he told her.

"Thompson later learned that Moran had sent a video he recorded of her performing oral sex on him to others, and that it eventually made its way back to the 101-model house, prompting months of online bullying from members of 101 Modeling, which continues to impact her mental well-being."

The conclusion of the petition says: "Section 1700.35 provides that a talent agency should not permit persons of bad character.... or intoxicated persons to be employed by the Agency. Drinking on the job with the talent is particularly galling given that Moran, more than 20 years their senior, should know better. What happened to Grace and Thompson is a clear violation of the provisions above of the Talent Agency Act.

"Section 1700.21 provides that the Labor Commissioner may revoke or suspend any license when it is shown that any of the following occur: (a) The licensee or his or her agent has violated or failed to comply with any of the provisions of this chapter, or (b) The licensee has ceased to be of good moral character. Both of the provisions of paragraphs 1700.21(a) and (b) have been violated here."

Felton told PornCrush: "Both performers feel like they not only need to advise the Department of Labor of the failures of Robert Moran and 101, but also to protect other performers from similar incidents of non-compliance."

Thompson and Grace both left 101 Modeling after the alleged assaults. Grace is now thriving as a member of Foxxx Modeling, having shot more than 100 scenes in 2025. Thompson is now represented by OC Modeling and is regarded as one of the industry's top rising stars.

Thursday's petition against Moran and 101 arrives with recent precedent on its side.

In a 2024 case brought by performer Nicole Doshi, the DLSE found her agency agreement with Motley Models was illegal from the outset and ordered the agency and its owner, Dave Rock, to return commissions and “booking fees,” along with attorney’s fees and costs.

And in a 2020 proceeding against agent L.A., direct agent Derek Hay, the DLSE found Hay violated the Talent Agency Act’s duty to protect performers’ health, safety, and welfare by steering models into situations the decision described as "unsafe."

In both matters, the DLSE sided with the performers, underscoring how aggressively California can use the Talent Agency Act when it concludes an agent’s conduct puts talent at risk.