Lawsuit Vs Jimmie Allen & Others

UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE
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,
alleges upon her personal knowledge as follows:
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
of a day-to-day manager, and how to support WOM’s clients.
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
Case 3:23-cv-00477 Document 1 Filed 05/11/23 Page 1 of 18 PageID #: 1

sexual advances on Plaintiff. Bowers and other Wide Open Music staff treated Jimmie Allen’s
sexual harassment as normal.
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
manipulation she would endure in order to keep her job.
5. Beginning in May 2020, during photoshoots, public appearances, 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
sexual questions, including whether she was a virgin.
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.
7. However, Allen’s behavior was not harmless.
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.

Nonetheless, neither WOM nor Bowers investigated whether and to what extent Allen was
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
October 26, 2022.
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.
JURISDICTION AND VENUE

14. This Court has subject-matter jurisdiction pursuant to 28 U.S.C. § 1331 because
this action arises under the laws of the United States. This Court also has supplemental
jurisdiction over the state law claims pursuant to 28 U.S.C. § 1367.
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.

18. Defendant Ash Bowers is a citizen of the United States and resident of Fairview,
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
her out as a representative of the business.
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
direction and input from her supervisor Bowers.
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
thus Plaintiff’s supervisor.
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

handle, among other things, the planning and execution of Allen’s publicity, global release
schedules, promos, social media plans, press, marketing, and touring.
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
was engaged was the regular business of WOM.
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.
B. WOM knew that Jimmie Allen regularly engaged in sexual

harassment but required Plaintiff to work with him anyway.
27. In April 2020, Bowers introduced Plaintiff to Allen.
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
Plaintiff that she could do it working as part of WOM’s “team.”
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
new iteration of WOM’s publishing department).
30. Bowers and other WOM employees treated Jimmie Allen’s sexual harassment as
normal.

C. WOM client Jimmie Allen openly and regularly sexually harassed and
sexually assaulted Plaintiff; WOM was put on notice but did not
protect her.
31. Beginning in May 2020, during photoshoots, public appearances, and
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
and public audiences.
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
conduct professionally and respectfully.
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
prevent pregnancy within 72 hours after unprotected sex.
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

had betrayed her faith.
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
terminated like the manager before her.
38. In April 2021, while at a filming, Allen opened a pornography website on
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
to Plaintiff’s supervisor, Bowers.
40. Allen ensured the hair and makeup assistant was fired for being a “snitch.”
Thereafter, Allen required anyone that he hired to sign a non-disclosure agreement.
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
to protect Plaintiff. Moreover, notwithstanding their knowledge of Allen’s history of sexual
harassment, neither WOM nor Mr. Bowers investigated to determine whether and to what extent

Plaintiff was being harmed.
43. Thereafter, Allen’s sexual harassment of Plaintiff significantly increased,
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
away, he held her down.
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
order to blackmail her to stay silent.
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
was uncomfortable and no, and crying uncontrollably.
46. However, Allen made clear that Plaintiff’s job was dependent on her staying
silent about his conduct.
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
whether and to what extent Plaintiff was being harmed.
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

gatekeeper and frontman at the artist’s events and appearances – making all such trips essential.
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
vaginal trauma on her person.
D. WOM retaliated against Plaintiff for complaining about the sexual

abuse.
52. On or about March 6, 2022, Plaintiff sat down with her boss, Bowers, and began
to tear up. Plaintiff explained how she felt humiliated by Allen.
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

this meeting, which was attended by Plaintiff, Bowers, and another WOM employee, Plaintiff
disclosed the details of Allen’s abuse. During this discussion, Bowers stated, “I can’t hear any
more of this,” and took a break.
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
stay/work from home. We will update you once that’s completed.”
59. On or about October 24, 2022, Bowers sent Plaintiff a text message, scheduling a
meeting at the office with her on October 26, 2022.
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.
62. In violation of 18 U.S.C. § 1591, Jimmie Allen knowingly, in or affecting
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
received by any person.
63. Jimmie Allen’s actions knowingly affected interstate or foreign commerce,
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.

64. Allen recruited, enticed, or solicited Plaintiff by any means, including but not
limited to by requiring her to perform her regular job activities (such as accompanying him to
official events) during which he would sexually assault or abuse Plaintiff.
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
knowingly benefits, financially or by receiving anything of value from participation in a venture
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. §

1591 and was using WOM to facilitate those acts.
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
violation of 18 U.S.C. § 1591.
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.
79. As a result of Allen’s conduct, Plaintiff suffered damages.

COUNT IV
ASSAULT
81. Allen intended to cause apprehension of harmful or offensive conduct against
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
85. Without her consent, Plaintiff was willfully detained by Allen while he battered,
assaulted, and attempted to assault her.
86. Allen willfully detained Plaintiff through physical force and/or through
intimidation. In many instances, Allen used such intimidation that Plaintiff stopped resisting
rather than risk injury or death.

COUNT VI
GROSS NEGLIGENCE
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
employment, agency, and/or representation of WOM, created a special, confidential, and
fiduciary relationship between Plaintiff and Bowers, and between Plaintiff and WOM, resulting
in WOM and Bowers owing Plaintiff a duty to use due care.
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
concern for whether an injury would result to Plaintiff.
92. WOM and Bowers’ conduct demonstrated a willful disregard for precautions to
ensure Plaintiff’s safety.
93. WOM and Bowers’ conduct, as described above, demonstrated a willful disregard
for substantial risks to Plaintiff.
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
substantial lack of concern as to whether an injury would result.
95. As a direct and/or proximate result of Defendants’ actions and/or inactions,

Plaintiff was damaged.
COUNT VII
NEGLIGENCE
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
ensure Plaintiff’s safety.
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
concern as to whether an injury would result.
COUNT VIII
NEGLIGENT FAILURE TO WARN, TRAIN, OR EDUCATE
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,

or educating Plaintiff about how to avoid such a risk.
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
posed of sexual misconduct.
COUNT IX
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(AGAINST WOM, BOWERS, AND ALLEN)
108. WOM’s, Bower’s, and Allen’s extreme and outrageous conduct intentionally or
recklessly caused severe emotional distress to Plaintiff.
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,
Bower’s, and Allen’s conduct exceeded all possible bounds of decency.
110. WOM, Bowers, and Allen acted with intent or recklessness, knowing that Plaintiff
was likely to endure emotional distress.
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
emotional distress would occur.
112. WOM, Bowers, and Allen’s conduct caused suffering for Plaintiff at levels that no
reasonable person should have to endure.

COUNT X
NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
(AGAINST WOM, BOWERS, AND ALLEN)
114. WOM, Bowers, and Allen’s conduct negligently caused emotional distress to
Plaintiff.
115. Defendants could reasonably foresee that their actions would have caused
emotional distress to Plaintiff.
116. WOM, Bowers, and Allen’s conduct caused suffering for Plaintiff at levels that no
reasonable person should have to endure.
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
as this Court deems appropriate.
Dated: May11, 2023 JANE DOE, Plaintiff
By:__/s/ John Spragens________

John Spragens
SPRAGENS LAW PLC
311 22nd Ave. N.
Nashville, TN 37203
Ph: (615) 983-8900
Fax: (615) 682-8533
[email protected]
Elizabeth A. Fegan (to be admitted

pro hac vice)
FEGAN SCOTT LLC
150 S. Wacker Dr., 24th Floor
Chicago, IL 60606
Ph: 312.741.1019
Fax: 312.264.0100
[email protected]
Counsel for Plaintiff

VERIFICATION PAGE
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.
Executed on May 02, 2023
Jane Doe

JS 44 (Rev. 04/21) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
Williams Bowers Management, LLC D/B/A Wide Open
Jane Doe
Music, Ash Bowers, Jimmie Allen, And John Does 1-100
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(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
Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ INTELLECTUAL 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/
362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI ✖ 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION 26 USC 7609 Act/Review or Appeal of
Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of
Other 550 Civil Rights Actions State Statutes
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
✖ 1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
28 U.S.C. § 1332(d)(2).
VI. CAUSE OF ACTION Brief description of cause:
Plaintiff brings this action for sex trafficking against Jimmie Allen and state tort violations against Jimmie Allen, Ash Bowers, and Wide Open Music.
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. Excess of $75,000 JURY DEMAND: ✖ Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
May 11, 2023 /s/ John Spragens
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case 3:23-cv-00477 Document 1-1 Filed 05/11/23 Page 1 of 2 PageID #: 19
JS 44 Reverse (Rev. 04/21)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then
the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.
V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statute.
VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service.
VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
Case 3:23-cv-00477 Document 1-1 Filed 05/11/23 Page 2 of 2 PageID #: 20

Lawsuit Vs Jimmie Allen & Others

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Lawsuit Vs Jimmie Allen & Others

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What allegations has the plaintiff made against the defendants?

What allegations has the plaintiff made against the defendants?

UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF TENNESSEE

alleges upon her personal knowledge as follows:

of a day-to-day manager, and how to support WOM’s clients.

Case 3:23-cv-00477 Document 1 Filed 05/11/23 Page 1 of 18 PageID #: 1

sexual harassment as normal.

manipulation she would endure in order to keep her job.

5. Beginning in May 2020, during photoshoots, public appearances, and

sexual questions, including whether she was a virgin.

7. However, Allen’s behavior was not harmless.

Case 3:23-cv-00477 Document 1 Filed 05/11/23 Page 2 of 18 PageID #: 2

October 26, 2022.

JURISDICTION AND VENUE

jurisdiction over the state law claims pursuant to 28 U.S.C. § 1367.

Case 3:23-cv-00477 Document 1 Filed 05/11/23 Page 3 of 18 PageID #: 3

her out as a representative of the business.

direction and input from her supervisor Bowers.

thus Plaintiff’s supervisor.

Case 3:23-cv-00477 Document 1 Filed 05/11/23 Page 4 of 18 PageID #: 4

schedules, promos, social media plans, press, marketing, and touring.

was engaged was the regular business of WOM.

B. WOM knew that Jimmie Allen regularly engaged in sexual

27. In April 2020, Bowers introduced Plaintiff to Allen.

Plaintiff that she could do it working as part of WOM’s “team.”

new iteration of WOM’s publishing department).

Case 3:23-cv-00477 Document 1 Filed 05/11/23 Page 5 of 18 PageID #: 5

31. Beginning in May 2020, during photoshoots, public appearances, and

and public audiences.

conduct professionally and respectfully.

prevent pregnancy within 72 hours after unprotected sex.

Case 3:23-cv-00477 Document 1 Filed 05/11/23 Page 6 of 18 PageID #: 6

terminated like the manager before her.

38. In April 2021, while at a filming, Allen opened a pornography website on

to Plaintiff’s supervisor, Bowers.

Thereafter, Allen required anyone that he hired to sign a non-disclosure agreement.

to protect Plaintiff. Moreover, notwithstanding their knowledge of Allen’s history of sexual

Case 3:23-cv-00477 Document 1 Filed 05/11/23 Page 7 of 18 PageID #: 7

43. Thereafter, Allen’s sexual harassment of Plaintiff significantly increased,

away, he held her down.

order to blackmail her to stay silent.

was uncomfortable and no, and crying uncontrollably.

silent about his conduct.

whether and to what extent Plaintiff was being harmed.

Case 3:23-cv-00477 Document 1 Filed 05/11/23 Page 8 of 18 PageID #: 8

vaginal trauma on her person.

D. WOM retaliated against Plaintiff for complaining about the sexual

to tear up. Plaintiff explained how she felt humiliated by Allen.

Case 3:23-cv-00477 Document 1 Filed 05/11/23 Page 9 of 18 PageID #: 9

more of this,” and took a break.

stay/work from home. We will update you once that’s completed.”

meeting at the office with her on October 26, 2022.

62. In violation of 18 U.S.C. § 1591, Jimmie Allen knowingly, in or affecting

received by any person.

By:/s/ John Spragens______