A class action lawsuit was filed today in Los Angeles County Superior Court against ICM, the talent agency’s EVP Jack Gilardi, and an outside personal manager named John Rockwell described as a “Hollywood hustler and close friend of Gilardi”. It alleges sexual battery, fraud, and a conspiracy under the Racketeer Influenced And Corrupt Organization (RICO) Act to “hip-pocket” actresses for sexual exploitation. TMZ first reported on the lawsuit, and I have now had a chance to read it. ICM gave this statement to me: the “allegations are outrageous and completely false. ICM denies any and all wrongdoing and will vigorously defend this action.”

Claire Robinson, a former Miss British Columbia 2004 and 23-year-old Canadian fashion model, is the plaintiff representing the class of other “similarly situated” women. These are defined as “all female actresses who were falsely promised representation by ICM through a ‘hip-pocket’ arrangement and who were sexually battered or sexually harassed by a co-conspirator.” The practice of hip-pocketing is described by the lawsuit as occuring “when an experienced, well-established senior agent extends the promise of representation to an actress without credit or experience” but never actually takes the “hip-pocketed” actress through the formal procedures of firm representation and then sexually exploits the woman. ICM sources tell me that Robinson is not listed in their records as a client.

Though the class action claims to “chronicle how young actresses wind up on the ‘casting couch’ to be sexually exploited through a criminal conspiracy of powerful men in the entertainment industry,” the complaint targets only one agent at ICM, the 79-year-old Gilardi. Robinson claims that, two years ago, she visited his office where he verbally agreed to be her agent and have ICM represent her. She alleges that on May 20, 2007, the 79-year-old Gilardi “made sexual advances” towards her in an ICM limousine while they were on their way to an awards show.

The rest of the complaint talks about the sexual advances and sexual battery, including a rape, that Robinson allegedly endured in 2007 and 2008 from John Rockwell, 74, who she says is Gilardi’s “professional and personal friend”. Rockwell is not employed by ICM but she describes him as her personal manager and she claims he arranged for Gilardi to rep her. There is no mention that she ever reported the year-old rape to local authorities. But the complaint says Robinson suffered a nervous breakdown because of her alleged “hip-pocketing” and has been receiving psychiatric treatment.

The lawsuit makes no allegations of sexual battery by Gilardi or ICM. It does allege “a criminal enterprise (RICO) involving a scheme to sexually exploit young actress [sic]. The scheme involves ICM, one of the top talent agencies in the world, and one of its legendary agents, Gilardi.” Robinson claims there were certain words exchanged between Rockwell and Gilardi — “the phrase ‘found a star’ was code to Gilardi that Rockwell had found a new victim for their scheme of sexual exploitation” — that show they were “co-conspirators”.

The complaint also claims that Robinson “has since learned that this scheme has ensnared other girls who were ‘hip-pocketed’ at ICM”, maybe as many as “hundreds”, without providing any details.