Attorney Jim Felton of G&B Law, who represents both performers, told PornCrush he hopes the DLSE's licensing department will take appropriate action and suspend 101 Modeling's license, which would make it difficult for Moran to ever work as an agent in California again.

"The purpose of this action was to hold Robert Moran and 101 Modeling accountable for actions taken against the two petitioners," Felton said. "In addition, it was to protect other performers from 101 Modeling and their failure to control and monitor what Mr. Moran was doing to performers."

The petition was addressed at a hearing July 8 via Zoom. Grace and Thompson appeared and were represented by Felton. What follows are findings by a state administrative officer.

"Respondents 101 Modeling, a California corporation, and Robert Moran, an individual, failed to appear at hearing," the determination states. "Based on the unrebutted evidence at hearing and on the papers on file, the Labor Commissioner adopts the following determination."

Moran is identified in the findings as 101 Modeling's chief executive officer, secretary and chief financial officer. The agency is described as a California corporation that "is and was at all relevant times a licensed talent agency in the State of California."

Regarding Grace, the findings align with the story she first gave PornCrush in February 2025. Grace had a shoot in Las Vegas on Feb. 5, 2025, booked by 101. The agency did not buy her a plane ticket; Moran drove her from Los Angeles himself. After the shoot, they drank on the Las Vegas strip. Despite having no reason to stay in Vegas, the determination says, Moran insisted on getting a room at the Flamingo Hotel — and Grace "made clear that she had no intention of having sex with Moran."

Then this line, which the state included in its findings of fact: "Moran even joked with the front desk attendant that (Grace) was refusing him sex."

In the room, the determination continues, Moran's demeanor changed and became more aggressive. "(Grace) credibly testified that Moran raped her." She later insisted they leave, and Moran drove her back to Los Angeles in the middle of the night.

The findings also address what 101 did next, which PornCrush reported in March 2025. Danny Frost, an employee of 101, contacted Grace within days. "Instead of supporting (Grace), Frost and 101 Modeling tried to protect Moran," the state found. Frost asked Grace if she'd be willing to recant her story, "going so far as to condition 101 Modeling's continued work for Grace on her recanting said allegations."

And this, which is new: "Frost alluded to such arrangements being made in the past with other artists who continued to work with 101 Modeling."

Thompson signed with 101 in the summer of 2025 and lived in the agency's model house. On Oct. 13, 2025, per the findings, Moran helped her find a different model house, introducing her to Samantha Phillips, who ran one in Los Angeles and who testified at the hearing that Thompson "had said she was no longer comfortable at 101 Modeling's model house."

That same day, Moran invited Thompson on a road trip to Huntington Beach, where he was driving another performer to a shoot. Lunch started with cocktails and escalated to shots.

The state's findings from there are blunt. Thompson does not remember going to a hotel. She recalls being "very intoxicated, barely conscious and unable to speak or resist," and she recalls Moran asking her to perform oral sex on him "which she did in her stupor, while he videotaped," and then recalls being on the bed with Moran having sex with her.

Eventually, Thompson was repositioned, with one of her knees pressed against the wooden baseboard. The pain was severe enough that it briefly pulled her out of her stupor, and she cried out for Moran to stop — "clearly withdrawing whatever dubious consent Moran may have believed he had," the determination states. "Moran continued having sex with (Thompson) despite her cries for him to stop, and (Thompson) lost consciousness again." Photos and video of the bruising, abrasions and scarring on Thompson's knee were entered at the hearing.

When Thompson regained consciousness and asked what happened, the findings say, Moran "replied laughingly that (Thompson) would have his babies."

Phillips corroborated the timeline, saying she was trying to reach both Thompson and Moran. Their phones went to voicemail, and 101 agent Fran Amidor told her she didn't know where either of them was. Thompson called Phillips at 1:30 a.m., saying she was in a hotel with Moran and in a bad situation. She took an Uber to Phillips' house and arrived at 2:30 a.m. PornCrush reported the same sequence in December, based on Thompson's account.

Thompson then reported the allegations to Amidor at 101. "Like Frost, rather than give the artist support in this awful situation, Fran and 101 Modeling gaslit her," the state found. "Fran characterized the events of October 13th as adults making mistakes and (Thompson) making bad choices."

Felton, the performer's lawyer, argued that two provisions of the Talent Agencies Act had been violated. The state rejected one and accepted the other.

Labor Code section 1700.33 says no talent agency shall send an artist to any place where the artist's health, safety or welfare could be adversely affected, where the agency could have found that out on reasonable inquiry. That is the provision the Labor Commissioner has used against adult agencies before — in Szarko v. Direct Models (TAC-50639) over a poker party where a performer was offered drugs and groped, and in Jane Does v. Derek Hay (TAC-52663), where the state found L.A. Direct Models breached the same duty.

Here, the state said no. "While 101 Modeling did not assure the health, safety and welfare of artists (Grace) and (Thompson), the risk to these artists arose not from the jobs they were sent to but from 101 Modeling's own agent, Moran. As such there is no violation of Labor Code section 1700.33."

In other words, the agency escaped the safe-workplace provision because the danger occurred in-house rather than on a set.

Section 1700.35 is where the petition found success. That provision says no talent agency "shall knowingly permit any persons of bad character, prostitutes, gamblers, intoxicated persons, or procurers to frequent, or be employed in, the place of business of the talent agency."

"Here, 101 Modeling knew, or should have known, that Moran was of bad character, drank excessively around artists, and had credible allegations of sexual assault leveled against him," the determination reads. "When that knowledge was imputed to the agency may not be exactly clear, but whether it was before (Grace) alleges she was raped (as Frost alluded to knowledge before that), or after she reported it to Frost, there is no situation where 101 Modeling did not know about allegations of Moran's bad character before he raped (Thompson)."

The order reads:

IT IS HEREBY ORDERED that: 101 MODELING, a California corporation licensed as an agent under the Talent Agencies Act, violated the Talent Agencies Act, specifically Section 1700.35, by letting Moran continue to actively work unsupervised with artists at the agency after being made aware of Moran's bad character, specifically allegations of sexual assault by (Grace) and others.

What the order leaves out matters as much as what it says. It names 101 Modeling, the corporate licensee, and not Moran individually, even though he was a named respondent. It awards no money. And it does not grant the relief the January petition asked for: that 101 lose its license and that Moran be barred from being a principal of any licensed California agency.

Under California law, a Determination of Controversy answers one question: whether a talent agency violated the Talent Agencies Act. Taking away the license is a separate process, handled by the Labor Commissioner's licensing unit.

But the clock is ticking.

Labor Code section 1700.44(a) gives either party 10 days after the determination to appeal to superior court, where the matter is heard de novo — a complete do-over rather than a review of the record. The determination was served by email on July 28, to Felton and to Moran at a 101 Modeling address. That puts the deadline at roughly Friday.

If Moran and 101 let it lapse, the finding stands. If they appeal, a Los Angeles Superior Court judge would hear the whole thing again, except that Grace and Thompson would have to testify a second time, and this time 101 would presumably show up.

Prior adult-industry determinations under this statute have produced voided contracts, disgorged commissions and attorney's fees. In Jane Does v. Hay, contracts were declared void, and commissions ordered returned.

Las Vegas police declined to forward Grace's case in February 2025, telling her it was a "he said, she said" and, she says, suggesting she find another job. Thompson took her account to Huntington Beach police in December but had no luck.

This is now on the record. For a year and a half this has been performers' accounts against an agent's silence. As of July 28, it is a finding by the State of California, adopted by the Labor Commissioner, that a licensed talent agency knew what Moran had been accused of and kept putting young women in cars and hotel rooms with him anyway.

Moran did not return a text message from PornCrush seeking comment.

Even before the determination, the publicity surrounding Grace's and Thompson's legal filing had impacted 101's roster. The agency listed more than 100 performers when Grace and Thompson filed their complaint in January. Seven months later, it sits at 44. Simply put, the agency has been gutted.

It has lost more than talent. AMA Models owner Brian Berke, who co-founded the agency with Moran more than a decade ago and often booked 101's models when they were in Florida, publicly ended his association with it in March. That same week, performer Alex Jett filed a request for a restraining order against Moran in Los Angeles Superior Court after a performer told Jett that Moran was trying to hire someone to murder him. Multiple sources have told PornCrush that Amidor left 101 in May and plans to launch her own agency. Frost is now with Ideal Image Models.

Grace's career has flourished since leaving 101. She shot more than 100 studio scenes over the next 18 months as a member of Foxxx Models. Last month she joined the Hussie Models roster. Thompson has worked sparingly in 2026 while battling health issues and recently left OC Modeling.

"At some point Robert has got to pay some sort of penalty, whether it's jail or losing his agency or whatever," she said. "Clearly, this is a pattern with him. And until people stop ignoring it, it's going to keep happening, again and again."

Last week, the state of California stopped ignoring it.